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Their Admission of Guilt Without Admitting to Guilt While Attempting to Silence Us
SETTLEMENT AND RELEASE AGREEMENT
THIS SETTLEMENT AND RELEASE AGREEMENT (this “Agreement”) is hereby made as
of this 16th day of December, 2024 (the “Effective Date”) by and between S. S and
S. S (hereinafter “Tenants”) and MT Propco I, LLC et al. dba Meadow View
Townhomes (hereinafter, “Landlord”). Tenants and Landlord are the “Parties” to this Agreement.
REASONS FOR THIS AGREEMENT
WHEREAS, Landlord is the owner of the property located at **** Marshall Ave., Newport
News, VA 23607 (hereinafter, “Premises”) and Landlord leases the Premises to Tenants under the terms
of a Residential Lease Agreement dated January 18, 2021, which was assigned to Landlord upon their
purchase of the Premises, (hereinafter, “Lease Agreement”), and any amendments thereto;
WHEREAS, various issues have arisen between the Parties, including but not limited to Tenants’
allegations that various housing conditions affected the habitability of the Premises, that Tenants
suffered damages as a result of said conditions, and/or that Tenants are entitled to credits on their
account;
WHEREAS, the Landlord and Tenants have agreed to resolve the issues between them as they
relate to the allegations listed above.
NOW THEREFORE
FOR AND IN CONSIDERATION of the mutual covenants and agreements contained herein
and other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged,
the parties agree as follows:
1. DISMISSAL OF TENANT’S ASSERTION AND COMPLAINT: Tenants shall dismiss with
prejudice the Tenant’s Assertion and Complaint, case number GV24013888-00, pending in
Newport News General District Court. The Parties agree the $950, which accounts for October
2024 rent, shall be disbursed to the Tenant. This disbursement is in addition to the $1900.00
(August 2024 and September rent), which has already been disbursed to Tenant. The Parties
agree to waive their right to appeal the Dismissal Order. The Parties agree to direct their Counsel
to submit a consent Dismissal Order.
2. DISMISSAL OF WARRANT IN DEBT: Tenants shall dismiss with prejudice the Warrant in
Debt, case number GV24020278-00, pending in Newport News General District Court. The
Parties agree to waive their right to appeal the Dismissal Order. The Parties agree to direct their
Counsel to submit a consent Dismissal Order.
3. RENTAL CONCESSION: Landlord agrees to give Tenant a $300 rental credit within 72 hours
of signing this Agreement.
4. TERMINATION OF LEASE AGREEMENT: The Parties mutually and expressly agree that
the Lease Agreement and all obligations of the respective Parties thereto are terminated effective
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March 15, 2025. The signing of this Amendment shall constitute actual notice,
acknowledgement, and agreement of the Lease termination and the vacate date.
5. VACATE DATE: Tenants shall return possession of the Premises to Landlord no later than 5:00
PM Eastern Time on March 15, 2025. “Return possession” means that all occupants have
vacated, the Premises are empty and clean, and all keys are returned to the Landlord. Should
Tenants fail to return possession of the Premises to Landlord by this date, then they will
automatically and immediately become holdover tenants pursuant to applicable Virginia law, and
Landlord shall have all rights and remedies available to them under Virginia Law, including but
not limited to, charging Tenant a liquidated damage penalty not to exceed an amount equal to
150 percent (150%) of the per diem of the monthly rent, for each day the Tenants remain in the
dwelling unit after March 15, 2025, and/or initiating an eviction action (Summons for Unlawful
Detainer) for immediate possession of the premises.
6. COVENANT NOT TO INCREASE RENT: Landlord shall not increase the monthly periodic
rent, which is currently $860.00, through the lease termination date of March 15, 2025.
7. ACKNOWLEDGEMENT OF ZERO BALANCE: Landlord hereby acknowledges that
Tenants do not owe any rent to Landlord as of the execution of this Agreement and that Landlord
does not intend to take legal action against Tenants unless Tenants materially violate the terms of
the Lease and/or Virginia Law.
8. SECURITY DEPOSIT: The security deposit shall be disbursed pursuant to Virginia law.
Tenants shall provide a forwarding address to the Landlord at the time they vacate the Premises
9. NO ADMISSION OF WRONG-DOING: All parties to this Agreement acknowledge that they
admit no liability of any sort, except as set forth herein, by reason of any disputes between the
parties and that settlement under the terms stated herein is made to terminate existing and further
controversy respecting all claims for damages that the undersigned have against the other
relating to the underlying dispute.
10. RELEASE: For the terms of this Agreement and other good and valuable consideration, the
Tenants, for themselves, their predecessors, successors, assigns, and agents, do hereby release
and forever discharge the Landlord, its respective officers, directors, stockholders, partners,
employees, agents, attorneys, insurers, and any other firm, person or corporation claiming by,
through or under them, their representatives and assigns, from any and all claims, demands,
damages, costs, expenses, loss of services, actions or causes of action, claims for action, known
or unknown arising from any act or occurrence or failure to act commencing from the beginning
of time to the execution of this Agreement, including, but not limited to, any claims that were or
could have been brought related to the Tenants’ allegations that various housing conditions
affected the habitability of the Premises, that Tenants suffered damages as a result of said
conditions, that Tenants are entitled to credits on their account, and/or anything related to their
tenancy at the Premises.
11. NON-DISPARAGEMENT: The Parties agree not to disparage each other in written or spoken
word, through any mediums including, but not limited to, social media, news organizations, or
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apartment review websites. The Parties agree to refrain from making derogatory comments about
any of the other parties to any person, entity, or organization other than to legal counsel. Any
written disparaging remarks must be removed from the internet within 24 hours of signing this
agreement.
12. NON-DISCLOSURE: The Parties further agree that they will not discuss or disclose any of the
facts or circumstances surrounding this Dispute or this Agreement. The non-disclosure
agreement shall continue and survive the execution of this Agreement. The parties recognize and
agree that a breach of the terms, covenants, and restrictions set forth in this paragraph of this
Agreement may not be reasonably or adequately compensated in damages and that, in addition to
any other relief of which such party may be entitled by reason of such violation, it shall be
entitled to permanent and temporary injunctive and equitable relief and compensatory damages.
13. ATTORNEY’S FEES AND COSTS. Should the Parties or their successors or assigns become
involved in future litigation concerning this Agreement or the Lease, the prevailing party will be
awarded its costs of litigation, including reasonable attorney’s fees.
14. MISCELLANEOUS.
A) SEVERABILITY. If any portion of this Agreement is void or deemed unenforceable for any
reason, the remaining portions shall survive and remain in effect, with any necessary
modification to become a part thereof and treated as though contained in this original
agreement.
B) CONSTRUCTION. It is recognized that each party had an equal opportunity to control the
language of this Agreement, and therefore, it shall be deemed and construed to have been
mutually drafted. In no event shall this Agreement be presumptively construed against any
party. This Agreement shall be construed as broadly as reasonably possible in favor of settling
and releasing any and all known or unknown claims, whether civil, criminal or administrative,
and shall be applied to prohibit any future complaints, claims, or causes of action in any legal
or equitable proceeding in a court of law.
C) VOLUNTARY AND ENTIRE AGREEMENT. The parties to this Agreement warrant and
represent that they have the capacity to sign and are authorized to sign and to bind the party
on whose behalf they execute this Agreement. The Parties have read, fully understand, and
voluntarily agree to the terms and conditions of this Agreement and have had the opportunity
to review and discuss it with their counsel. The Parties further acknowledge that this
document contains the entire, integrated agreement, between the parties and that there has
been no other promises, representations, or agreements related to this Agreement, except as
specifically set forth herein.
D) COUNTERPARTS. The parties hereby acknowledge and agree that this Agreement may be
singed in counterparts with all the executed originals constituting the whole of the agreement.
E) GOVERNING LAW: This Agreement shall be governed in all respects and shall be
interpreted in accordance with the laws of the commonwealth of Virginia.
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F) MODIFICATION: This Agreement constitutes the entire agreement between the parties
hereto and shall not be modified except upon written agreement of the parties.
G) SUCCESSORS: This Agreement inures to the benefit of and shall be binding upon the parties
hereto and their respective successors and assigns.
H) ELECTRONIC SIGNATURE: Each party agrees that this Agreement and any other
documents to be delivered in connection herewith may be electronically signed, and that any
electronic signatures appearing on this Agreement or such other documents are the same as
handwritten signatures for the purposes of validity, enforceability, and admissibility. A signed
copy of this Master Contract or any other ancillary agreement transmitted by facsimile, email,
or other means of electronic transmission shall be deemed to have the same legal effect as
delivery of an original executed copy of this Master Contract or such other ancillary
agreement for all purposes.
WITNESS the following signatures and seals, effective as of this 16th day of December,
2024.
We did not sign this. I will not be silenced. They went to court and lied so I come here to tell as many people as I can, the truth.