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INSPANCE NOT iif--OU'Rrf [) VORK i1XY PROCEEIO Cl ta4IK OF Couli 1. JUL 15 2019 G 0' CA;y (o) ��e,k.vr 1A e�tw- SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS N-2019-124 This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made and entered into by and between TERESA SANTANA-REGALADO (hereinafter "Plaintiff'), and CITY OF SANTA ANA (hereinafter "Defendant"). 3YITNES8EIH: WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State California, County of Orange, Central Justice Center known as TERESA SANTANA-REGALADO v, CITY OF SANTAANA, Case No, 30-2018-00996385-CU-PO-CJC (the "Action"). WHEREAS, Plaintiff and Defendant (collectively, the "Parties"), desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described above. NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and other good and valuable consideration, receipt ofwhich is hereby acknowledged, and to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows: IR T: This Agreement and compliance with Uris Agreement shall not be construed as an admission by Defendant of any liability whatsoever, or as an admission by Defendant of any violation of the rights of Plaintiff or any person, or violation of any order, law, statute, duty, or contract whatsoever against Plaintiff or any person. Defendant specifically disclaims any liability to Plaintiff or any other person for any alleged- violation of the rights of Plaintiff or any person, or for any alleged violation of any order, law, statute, duty, or contract on the part of any employees or agents of Defendant, Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. SECOND- (a) Each party will exchange a fully signed executed copy or original of this Agreement. Defendant cannot proceed with processing payment as set forth herein without first receiving a fully executed copy of the Agreement from Plaintiff. (b) Following receipt of, or in exchange for, an executed copy of a Request for Dismissal form from Plaintiff dismissing this Action with prejudice, Defendant will make available a check in the amount of Thirty Thousand Dollars ($30,000) made payable to "TERESA SANTANA- REGALADO AND CALIFORNIA LAWYERS GROUP, INC." The City o£Santa Ana will file the Request for Dismissal after delivering the check. Plaintiff and Defendant agree that this Agreement constitutes full and complete settlement of all claims and damages made against Defendant in this Action. Plaintiff will not seek any further compensation for any other claimed damages, costs, or attorney's fees in connection with the matters encompassed in this Agreement. Page 1 of