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A-2019-247 r t:8 4 20B O LUOt,trvtAvCt?lla vi�k+lr.+ra.- SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made and entered into by and between RAMONA MARQUEZ (hereinafter "Plaintiff'), and CITY OF SANTA ANA (hereinafter "City"). WHEREAS, Plaintiff filed an action against City in the Superior Court of the State California, County of Orange, Central Justice Center, styled RAMONA MARQUEZ v. CITY OF SANTAANACase No. 30-2018-01024447-CU-PO-CJC (the "Action). WHEREAS, Plaintiff and City (collectively, the "Parties"), desire to settle fully and finally all differences between them, including, but in no way limited to, those differences set forth in the Action. NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and other good and valuable consideration, receipt of which is hereby acknowledged, and to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows: FIRST: This Agreement and compliance with this Agreement shall not be construed as an admission by City of any liability whatsoever, or as an admission by City 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. City 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 City. 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 from Plaintiff dismissing this Action with prejudice, Defendant will make available a check in the amount of Two Hundred and Five Thousand Dollars ($205,000) made payable to "RAMONA MARQUEZ AND THE LAW OFFICES OF GENE J. GOLDSMAN." Plaintiff will file the Request for Dismissal after delivering the check Plaintiff and City agree that this Agreement constitutes full and complete settlement of all claims and damages made against City in the Action. Plaintiff will not seek any further compensation for any other claimed damages, costs, or attorneys fees in connection with the matters encompassed in this Agreement.