GENERAL RELEASE

NOTICE: THIS IS AN IMPORTANT LEGAL DOCUMENT. BY SIGNING THIS

DOCUMENT YOU AGREE THAT YOU HAVE READ AND UNDERSTAND, IN FULL,
THE TERMS OF THIS DOCUMENT.

RELEASORS:, a/k/a John Doe

, a/k/a Jane Doe

RELEASORS’ ATTORNEYS: The Fierberg National Law Group,

PLLC - Monica Beck, Doug Fierberg
Law Office of Eddie Schmidt
Eddie Schmidt

RELEASEES: Hamilton County Department of

Education, its employees, agents and
school board members and the
Tennessee Risk Management Trust as
insurers of Hamilton County
Department of Education, only

SETTLEMENT AMOUNT: $750,000.00 for Releasor’s personal

physical and psychological injuries.

INCIDENT: 2014-2015 School year while

RELEASOR was a student within the
Hamilton County Department of
Education. Specifically, as a member
of Ootelwah Boys High School
Basketball team, claims
inter alia the Hamilton County
Department of Education violated
federal and state laws including but
not limited to the Tennessee
Governmental Tort Liability Act, the
Fourteenth Amendment to the United
States Constitution under 42 U.S.C. §
1983 and Education Amendments of
1972 (Title IX) 20 U.S.C. § 1681, as
alleged in a civil action entitled John
Doe, by and through his next friend,
Jane Doe, vs. Hamilton County Board
of Education, et al., in the United
States District Court for the Eastern
District of Tennessee, Chattanooga
Division, Case Number 1:16-CV-00373.
 KNOW ALL MEN BY THESE PRESENTS that the RELEASORS, on behalf of

themselves, their heirs, executors, administrators, successors and assigns for and in

consideration of the SETTLEMENT AMOUNT noted above, have hereby remised,

released and forever discharged RELEASEES of and from any and every claim, demand,

right or cause of action, of whatsoever kind or nature, by reason of injuries sustained by

RELEASOR arising from the INCIDENT. As further consideration for the making of said

settlement and payment, it is expressly agreed:

1. That all claims, past, present or future, are disputed and this full and final

settlement thereof is not intended to, nor shall it constitute, an admission of liability or

responsibility at any time or in any manner whatsoever.

2. That this General Release (hereinafter “Release”) is expressly intended to

cover and include all claims several or otherwise, past, present or future, which can or may

be asserted by RELEASORS as a result of injuries or the effects or consequences thereof

arising from the INCIDENT.

3. That this Release is intended to cover all and any future injuries, not now

known to either the RELEASEES or RELEASORS but which may later develop or be

discovered arising from the Incident.

4. That it is further agreed that this release is inclusive of any and all claims for

subrogation, or other claims for reimbursement that any other person or entity may have

by way of its prior payments or extensions of credit to or on behalf of RELEASORS arising

from the INCIDENT, specifically including, but not limited to, any claim by any government-

funded agency or bureau such as TennCare, Medicare, or Medicaid, and any claim by any

and all healthcare providers including but not limited to LeConte Medical Center, University