RELEASE OF ALL CLAIMS

THIS INDENTURE WITNESSETH that in consideration of the payment to MATTHEW

SETH SARELSON PA of the sum of NINETEEN THOUSAND, NINE HUNDRED EIGHTY
NINE AND 89/100 DOLLARS ($19,989.89), receipt whereof is hereby acknowledged, I,
STEVEN MIRO, for myself and for my heirs, personal representatives and assigns, release and
forever discharge the CITY OF MIAMI, its current and former elected officials, departments,
officers, agents, servants, and employees, its contractors, lessees, and any other person, firm or
corporation charged or chargeable with responsibility or liability, their respective heirs,
representatives and assigns (collectively the “RELEASEES”), from any and all claims, demands,
causes of action, on account of, or in any way growing out of PUBLIC RECORDS REQUEST 18-
1201 (“PRR 18-1201”) of on or about July 30, 2018 in which the RELEASOR alleged that the
City violated Florida’s Public Records Act (the “incident”), and as a consequence of which suit
was filed in the Circuit Court in and for Miami-Dade County, Case No. 18-034893 CA 01 (27).
This release covers Miro’s claim for fees and costs in connection with PRR 18-1201 and Miami-
Dade County Case No., 18-034893 CA 01 (27) and nothing else.

To procure payment of the said sum, the RELEASOR hereby declares and covenants as
follows:

1. That the RELEASOR is of full age, under no legal disability and is competent to
attest to these matters;

2. That the RELEASOR has not been influenced in any manner, or to any extent, in
making this Release by any representations or statements regarding damages, or regarding any
other matters, by the RELEASEES, or by any person or attorney(s) representing them, or any of
them individually, or by anyone employed by them;

3. That RELEASOR has had the benefit of counsel of his own attorney(s), and that
RELEASOR fully understands the terms of this Release, and that RELEASOR is making full and
final settlement of all claims of every nature and character against the RELEASEES;

4. That there is no outstanding attorney’s lien in connection with the sum paid herein
to the RELEASOR;

5. That this Release is made to induce the said RELEASEES, and those making
payment for, or on behalf of, said RELEASEES, to settle with RELEASOR, and to pay said sum
of money to RELEASOR without securing any of the following (which, if they exist, have been
fully satisfied or released):

a. Any release of lien from any attorney; and

b. In the event any such lien, or liens, described above not be satisfied,
released, or otherwise extinguished, THE RELEASOR SPECIFICALLY UNDERTAKES
AND AGREES TO INDEMNIFY, HOLD HARMLESS AND DEFEND the said

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 RELEASE OF ALL CLAIMS
CASE NO.: 18-034893 CA 01 (27)

RELEASEES, from any action or claim asserting such liens against the RELEASEES,
including all losses, costs, expenses, judgments and attorney’s fees incurred as a result of
the assertion thereof:

6. That this Release contains the entire agreement between the parties hereto regarding
the subject of the agreement and the terms of this Release are contractual and not a mere recital;

7. RELEASOR understands that the RELEASEES admit no liability of any sort by

reason of said incident and that said payment and settlement provided for herein in compromise is
made to terminate further controversy respecting all claims for damages that RELEASOR has
heretofore asserted or that RELEASOR, or his personal representative(s), might or could hereafter
assert because of the said incident.

SIGNED AND SEALED this ________ day of December, 2020.

(CAUTION: READ AND UNDERSTAND THIS DOCUMENT FULLY BEFORE SIGNING)

_____________________________________
Name: Steven Miro
STATE OF FLORIDA )
) ss:
COUNTY OF MIAMI-DADE )

The foregoing instrument was acknowledged before me this _____ day of December, 2020,
by Steven Miro, who is personally known to me or who has produced ___________________ as
identification and who did/did not take an oath.

SIGNATURE____________________________________
PRINT____________________________________
Notary Public State of Florida
My Commission Expires: ______________

My Commission Expires: __________________________

_____ Did Take an Oath
_____ Did Not Take an Oath
_____ Personally Known
_____ Produced I.D., Type of I.D. Produced: __________________________

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