Draft Settlement Agreement and Mutual Release 

Lakewood Land Partners & Green Mountain Water and Sanitation District 

June 30, 2025 

The key terms of the Settlement Agreement and Mutual Release between Lakewood Land Partners LP (“LLP”) and the Green Mountain Water and Sanitation District (the “District”) are as follows:  

1. The District and LLP agree to take formal action to exclude LLP’s development, “The Bend” at Union and Sixth Avenue (the “Development”), from the District. The exclusion will become effective upon final action by the City of Lakewood and Consolidated Mutual Water Company, and organization of the Bend @ Lakewood Metropolitan District, as necessary, to provide water and sanitary sewer service to the Development. § 3(a)(i). 
    
2. The District agrees to cooperate in good faith with the exclusion process and to hold a public hearing on LLP’s exclusion request no later than August 31, 2025. § 3(a)(iv). 
     
3. LLP will make a deposit of money to the District sufficient to pay the costs of the exclusion proceedings as required by statute. § 3(a)(ii). 
    
4. Within five business days following the effective date of LLP’s exclusion from the District, LLP will seek to dismiss its legal case with prejudice and release all claims and causes of action against the District, its directors, and employees related to water and sanitary sewer service to the Development. § 3(b)(ii), (c). 
    
5. Upon the effective date of LLP’s exclusion from the District, LLP will release its rights under the Partial Assignment and Assumption of Water and Sewer Capacity and Utility Service Agreement, dated April 24, 2024, between LLP and the Administrator of General Services (“GSA”). LLP also agrees to cooperate with the District in negotiations with the U.S. regarding release and/or reallocation of capacity reservations thereunder. § 3(d).