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TDC :aaa 11(21)00 <br />million annual passengers and 1.0 million tons of cargo per year at a level of service consistent with the <br />Port's planning standards. The City agrees not to maintain any action of law or equity to oppose future <br />actions regarding the ADP, save and except to enforce the provisions of the Settlement Agreement. <br />30. Mutual Releases. <br />a) The Port releases and forever discharges the City and its past, present and future elected <br />and appointed officers, directors, commission members, employees, servants, agents, representatives, • <br />attomeys, and successors from any and all claims, demands, obligations, and causes of action of any <br />nature whatsoever, past, present or future, whether known or unknown, whether existing or arising <br />hereafter, whether based in tort, contract, statute, Constitution or other legal theories of recovery and <br />whether for compensatory or punitive damages, which arise out of or in any way relate to the matters at <br />issue in any or all of the actions. <br />b) The City releases and forever discharges the Port, the Board of Port Commissioners, and <br />each of them, and their past, present and future elected and appointed officers, directors, board members, <br />employees, servants, agents, representatives, attorneys, successors, and assigns from any and all claims, <br />demands, obligations, and causes of action of any nature whatsoever, past, present and future, whether <br />known or unknown, Whether existing or arising hereafter, whether based in tort, contract, statute, <br />Constitution, or other legal theories of recovery and whether for compensatory or punitive damages, which <br />arise out of or in any way relate to the matters at issue in any or all of the actions in Alameda Case. Nos. <br />793056 -0, 793028 -7, 793033 -9, 793046 -3, 815052 -9, 815330 -6 and 815053 -8. <br />c) The mutual releases in subparagraphs (a) through (b) of this Section specifically include <br />any and all claims, whether or not now known or suspected to exist and whether or not specifically or. <br />City of San Leandro and Port of Oakland <br />Settlement Agreement Page 31 <br />29848