LE, THERESA V. CITY OF SANTA ANA, (CVRA)

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The City's district boundaries shall be redrawn in accordance with the same criteria set forth in this Agreement, except as may otherwise be required under relevant law and provisions of the Santa Ana City Charter that do not violate the law. 14. Attorneys' Fees, Costs, and Expenses. California Elections Code section 14030 mandates the award of attorneys' fees, costs and expenses to prevailing plaintiffs in any action to enforce sections 14027 and 14028. The City agrees to pay Plaintiff an award of reasonable attorneys' fees, litigation expenses, and costs in the amount of $265,000 in settlement for: (1) all attorneys' fees and costs and expenses incurred in this case to date, and (2) all attorneys' fees, costs or expenses that Plaintiff may incur in participating in the mapping discussions, the Community Outreach Meetings, Public Hearings and/or the execution of this Agreement and the execution or filing of the Stipulated Judgment discussed herein. Any other attorneys' fees, costs and expenses incurred relating to the CVRA lawsuit are deemed to be included within this $265,000 total unless expressly excluded from this total as provided herein. The City shall pay to Plaintiff's counsel the full amount of $265,000 within ten (10) days of execution of this Agreement. After execution of this Agreement by the Parties hereto, each Party shall bear its own attorneys' fees, costs and expenses of whatever nature or cause, including, without limitation, attorneys' fees, costs and expenses associated with the ballot arguments, the ballot measure and the November 6, 2018 election, or participation in the process of establishing the City's electoral districts. Exclusive of the $265,000 payment for attorneys' fees, costs and expenses provided herein, Plaintiff reserves the right to seek attorneys' fees, costs and expenses as to enforcement of this Agreement should Plaintiff contend that Defendants have not complied with the terms of this Agreement. In the event Plaintiffs must resume litigation for non- compliance with this Agreement, Plaintiffs shall be entitled to seek all fees and costs expended in furtherance of this lawsuit incurred from the date of execution of this Agreement, up to and including any fees incurred by Plaintiff in connection with filing a motion for attorney's fees. 15. Stay of Proceedings. Upon execution of this Agreement, the parties shall submit a stipulation and proposed order to the Court requesting that all litigation related to the above captioned lawsuit between the Parties shall be suspended and the above -entitled action stayed until a date certain after the November 6, 2018 election, at which date the action shall be dismissed within ten (10) days (if the ballot measure passes, and subject to this Court's retention of jurisdiction pursuant to this Agreement), or the Stipulated Judgment shall be filed (if the ballot measure does not pass) as detailed in Paragraph 8. The Parties shall execute a stipulation to the effect that the matter may be stayed between the date of the execution of this Agreement and the November 6, 2018 election. This litigation bar does not apply to other litigation activities 9