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A. Payment: CITY OF SANTA ANA, shall pay to the Client Trust Account for <br />the Law Office of Corey W. Glave the total sum of three hundred seventy thousand dollars <br />($370,000.00), within twenty (20) days of the date upon which the Settlement Agreement <br />is fully executed by the parties, to cover all damages, statutory penalties, costs and <br />attorney fees in pending litigation against the DEFENDANTS. After said payment is <br />received by counsel for the OFFICERS, counsel of record for the Agreeing Parties shall <br />immediately file Notices of Settlement in the above referenced actions. <br />B. Additional Terms of Settlement: The Parties hereby agrees as follows: <br />1. Officer Brandon Sontag's reinstatement to his position as police <br />officer with the Santa Ana Police Department with no loss of benefits or seniority will <br />become permanent. The ancillary duty of Defensive Tactic Instruction removed from <br />Sontag will be reinstated. Sontag shall not be required to serve any suspension hours, <br />and to the extent already he already served said hours, he will be reimbursed for said time <br />through the payment required in section A, above; <br />2. Officer Nicole Quijas' reinstatement to her position as police officer <br />with the Santa Ana Police Department with no loss of benefits or seniority will become <br />permanent. Quijas shall not be required to serve any suspension hours, and to the extent <br />already he already served said hours, she will be reimbursed for said time through the <br />payment required in Section A, above; <br />3. The underlying investigation and discipline, as set forth in Internal <br />File: PSU 2015-0052, shall not be used for any personnel purposes against the <br />OFFICERS; <br />4. The City of Santa Ana and Santa Ana Police Department, and their <br />agents, representatives, attorneys, or anyone acting on their behalf, shall maintain all <br />copies of PSU 2015-0052 in a confidential status and shall not disclose any information <br />from PSU 2015-0052 unless pursuant to California Penal Code Section 832.7(a), a valid <br />Court Order, a waiver by the employee, or other lawful government process requested by <br />a government or law enforcement agency. As required by California Penal Code Section <br />832.5(b), PSU 2015-0052 shall be retained for five years after the date of the incident, to <br />wit, May 26, 2015. After the conclusion of the five year period, PSU 2015-0052 shall be <br />purged as governed by CITY and DEPARTMENT destruction policies, court orders, and <br />all applicable law, unless a Court order forbids the City from purging PSU 2015-0052.; <br />5. The Santa Ana Police Department agrees to meet with counsel for <br />the SAPOA and the OFFICERS to discuss modification of the DEPARTMENT's <br />administrative investigation procedures and policies to insure that a) officers, both <br />witnesses and focus officers (as those terms are used by the Santa Ana Police <br />Department) are informed of the full nature and scope of internal affairs investigation in a <br />Page 3 of 7 <br />