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all Plaintiffs' claims against the Q.T. Defendants and City Defendant; the Class's claims <br />against the Q.T. Defendants and City Defendant; and Defendants' actual and potential claims <br />against the other Defendants, on the terms set forth below, subject to Court approval under <br />Rule 23 of the Minnesota Rules of Civil Procedure. <br />I. RECITALS <br />WHEREAS, on April 17, 2020, Plaintiffs commenced this Tenant Class Action by <br />filing a Class Action Complaint alleging claims against Defendants for violation of tenant <br />rights, misrepresentation, and discrimination in connection with Q.T. Defendants alleged <br />tenant removal system at Pike Lake Apartments in New Brighton, Minnesota; <br />WHEREAS, Defendants answered the Class Action Complaint denying the <br />allegations contained therein; <br />WHEREAS, the Parties have engaged in litigation since April 2020, which permitted <br />Plaintiffs, Class Counsel, Defendants, and Defendants' Counsel to evaluate the claims and <br />potential defenses and to meaningfully conduct informed settlement discussions from <br />September to December 2020; <br />WHEREAS, Plaintiffs and Defendants mediated their dispute with experienced <br />mediator John Harens of Harens Mediation Center, LLC, in an all -day mediation session on <br />September 17, 2020 and a number of follow-up settlement communications with counsel for <br />the Parties; <br />WHEREAS, after intensive settlement negotiations, the Parties agreed to certain <br />monetary settlement figure and non -monetary settlement conditions; <br />WHEREAS, the Class Representatives believe that the claims settled herein have <br />substantial merit, but they and their counsel recognize and acknowledge the expense and <br />length of continued proceedings necessary to prosecute the claims through trial, appeal, and <br />2 <br />