IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION
HUMAN RIGHTS DEFENSE CENTER

§
§
vs.
§
§
GRAYSON COUNTY, TEXAS; TOM WATT §
in his individual capacity; and WILLIAM A
§
BENNIE, in his official capacity as Sheriff of §
Grayson County, Texas.
§

CIVIL ACTION NO. 4:24-CV-00828

MEDIATED COMPROMISE SETTLEMENT AGREEMENT AND RELEASE
1. The parties to this Mediated Compromise Settlement Agreement are Human Rights Defense
Center {"Plaintiff'') and Grayson County, Texas; Tom Watt, in his individual capacity; and
William A. "Tony" Bennie, in his official capacity as Sheriff of Grayson County, Texas
{"Defendants"), all of whom are collectively referenced herein as "the Settling Parties."
2. The consideration to be given for this settlement is as follows: Plaintiff and its attorneys, or
said party's designee(s), shall be paid the aggregate sum of $290,000.00 USD to be tendered not
later than 14 days following Plaintiff's return of each payee's Form W9, and check drafting
instructions. Said settlement payment shall be tendered by the Texas Association of Counties
Risk Management Pool on behalf of all Defendants.
3. The above-styled lawsuit shall be resolved by an Agreed Stipulation of Dismissal under
FRCP 41 (a)(1 )(A)(ii), with all taxable court costs, expenses and attorneys' fees to be paid by the
party incurring them. Nothing in this Agreement shall affect or alter the Permanent Injunction
issued by the Court in this matter on March 13, 2025.
4. The Settling Parties agree that this settlement represents the compromise of a disputed claim,
and that any payments or other consideration exchanged hereunder shall not constitute or be
construed as an admission of fault or liability by either party, which fault or liability remains
expressly denied.
5. In exchange for the mutual promises and other consideration described herein, the Settling
Parties hereby mutually agree to release, and discharge one another and the Texas Association
of Counties Risk Management Pool, as well as all of their respective attorneys, agents, employees,
insurers, risk pools, officers, directors, elected officials, contractors, and partners, and all of their
related or affiliated entities, and all predecessors and successors in interest (hereafter collectively
the "released parties"), from any and all claims, demands, or causes of action existing between
them on the date of this Agreement, whether known or unknown, asserted in this action or not,
fixed or contingent, liquidated or unliquidated, of any kind or description, to the extent that such
claims, demands or causes of action are related in any way to any of the facts, events, transactions,
allegations or damages which form the basis for any of the claims asserted in this litigation.

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6. Each signatory to this Agreement warrants and represents that: (a) he/she has the authority
to bind the party for whom that signatory acts; and (b) the claims, suits, rights and/or interests
which are the subject of this Agreement are owned by the party asserting same, and have not
been assigned, transferred or otherwise encumbered, except for assignments to a party's attorney
as security for fees and expenses incurred in this case.

7. It is contemplated and intended that this Agreement be the final settlement agreement between
the Settling Parties, and it shall constitute a full and final release of all claims which have been, or
could have been, asserted regarding any and all events and/or circumstances occurring prior to
the date of this Agreement
8. If any disputes arise regarding the interpretation and performance of this Agreement or any of
its provisions, or regarding the terms of settlement generally, the Settling Parties agree to attempt
to resolve any such dispute by telephone conference with the Mediator. If the parties cannot
resolve their differences by phone conference, then each agrees to participate in a half-day
mediation session with the Mediator within 30 days, and the parties agree to share the costs of
such mediation equally. If a party refuses to mediate as provided herein, then that party agrees
to forfeit the right to recover attorneys' fees or court costs in any litigation brought to enforce or
construe this Agreement. Otherwise, if mediation is unsuccessful, then the prevailing party shall
be entitled to recover reasonable attorneys' fees, court costs and litigation expenses relating to
enforcement of this Agreement, including the cost of the unsuccessful second mediation.

9. This Agreement is made and performable in Grayson County, Texas, and shall be construed
in accordance with the laws of the State of Texas.

10. Each signatory to this Agreement certifies that the agreement represented by this document
is made freely, without duress, after consultation with counsel to the extent that each party desired
to do so. Each party acknowledges that the Mediator has not given legal or tax advice, is not an
attorney for any party, and that no party is relying upon any promises or statements by the
Mediator in their decision to enter into this Agreement.

11. This Agreement is "signed" by authorized representatives of the parties and approved as to
form by counsel, on this 31 st day of July, 2025.

~ennie, in his official capacity

Paul
Hum

As Sheriff of Grayson County,~

~2 - ~
Tom Watt,

indiwJually

----/
Counsel for Plaintiff

c~~
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Mediator:

James J. Juneau
GILBERT MEDIATION GROUP
12801 N. Central Expressway
North Central Plaza 111, Suite 1400
Dallas, Texas 75243
(214) 303-4500
iiuneau@gmgtexas.com

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