NEIGHBORS SUPPORTING THE RECALL OF JUAN VILLEGAS

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SECOND: (a) The parties agree to waive their right to a hearing on Neighbors' Motion for Attorney's fees currently scheduled for December 2, 2019, at 2:00 p.m, in Orange County Superior Court, Central Justice Center, Department C15. (b) City agrees to pay to Neighbors' attorney of record, Mark S. Rosen, thirty-nine thousand dollars and zero cents ($39,000.00) made payable to the "Mark S. Rosen Client Trust Account" in full and complete satisfaction of Neighbors' claim for attorney's fees and costs in this Matter. In consideration of such promise and the other rights conferred by this Agreement, Neighbors agrees to release, remise, and forever discharge City, Mitre and Gomez, from any and all claims for attorney's fees or costs in this Matter, which may be due to Neighbors by reason of such claim/complaint. Neighbors agree to provide all necessary paperwork including a signed copy of this Settlement Agreement, a W-9, and any other paperwork necessary to process payment by Thursday, September 26, 2019 at 10:00 a.m., failure to do so will result in an extension of City's time to pay the settlement amount equal to the delay in submitting the paperwork. (c) The City agrees to pay in full the amount listed in subsection (b) above on or before Monday, September 30, 2019 by 11:59 p.m. to Neighbors' attorney Mark S. Rosen, subject to a potential extension if there is a delay on the part of Neighbors in submitting the necessary paperwork. (d) Neighbors agree to provide City's attorney with a signed Notice of Withdrawal of its Motion for Attorney's fees an September 30, 2019 by noon. City agrees not to file said Notice until payment has been made to Neighbors' attorney pursuant to subsection (b) of this Section of the Agreement. THIRD: Neighbors represent that it has not filed any complaints, claims, or actions against City as a result of the incident set forth in the complaint including any of its officers, agents, directors, supervisors, employees, or representatives of City with any state, federal, or local agency or court and that it will not do so at any time hereafter as it relates to this action and that if any agency or court assumes jurisdiction of any complaint, claim, or action against City, its employees, volunteers, officials, or agents on Neighbors' behalf, Neighbors will direct that agency or court to withdraw and dismiss with prejudice the matter. FO Wr : The parties hereto hereby agree that all rights under Section 1542 of the Civil Code of the State of California are hereby waived, Civil Cocle Section 1542 provides as follows; "A general release does not extend to claims which the creditor does not Imo%s or suspect to exist in his or her favor at the tints of executing the release, which if known by hinr or her must have materially affected his or her settlement Page, 2of5