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causes of action, suits, debts, dues, sums of money, attorneys' fees, accounts, bonds, bills, promises,
<br />controversies, covenants, contracts, agreements, damages (whether compensatory, economic, restitution,
<br />punitive, or otherwise), pre judgment or post-settlement interest, expenses, claims, and demands
<br />whatsoever, whether now known or unknown, existing at, or at any time prior to, the date hereof, in law,
<br />in equity or otherwise, which CCI, its parents, subsidiaries, affiliates, successors, and assigns had or
<br />have upon or by reason of any fact, matter cause or thing whatsoever, including but not limited to: (i)
<br />any and all claims based upon the U.S. Constitution including, but not limited to, the Takings, Due
<br />Process, and Equal Protection Clauses, (ii) any and all contract claims, whether express, implied, quasi-
<br />contract, promissory estoppel, specific performance, unjust enrichment, or otherwise; (iii) any and all tort
<br />claims, including but not limited to, those for gross negligence, negligence, willful and wanton
<br />misconduct, intentional tort, tortious interference with contractual relations and the like; (iv) any and all
<br />claims arising with respect to any deprivation of CCI's rights under the Ohio Constitution; and (v) any
<br />and all other claims, whether based on federal, state, or local statute, rule, regulation, or law, whether
<br />sounding in tort, contract, quasi-contract, equity, civil rights, discrimination, public policy, mandamus,
<br />injunction, prohibition, declaratory relief, quo warranto, administrative appeals, or otherwise, whether
<br />known or unknown, arising from any circumstances or facts, acts or omissions, pertaining to the
<br />relationship between and among the Parties, the Litigation and the allegations and controversies related
<br />or giving rise thereto (collectively, the "Released Claims"). CCI further specifically covenants and
<br />agrees that neither they, nor anyone on their behalf, will sue the City or any of the aforementioned
<br />persons released herein, i.e. officials, members, officers, employees, agents, representatives, attorneys,
<br />successors, or assigns, in either their personal or official capacities, with respect to the Released Claims.
<br />(B) Later Discovered Facts.
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