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N-2024-021 JAN 18 W4 0..Ch00) mnr' C p.14,1\esen� SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims ("Agreement") is made and entered into by and between MA RAMIREZ ("Plaintiff') and CITY OF SANTA ANA ("Defendant"), WITNESSETH: WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State California, Countyof Orange, Central Justice Center styled Ma Ramirez v. City ofSantaAna, et al., Case No. 30-2021-01191294-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 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: 1. This Agreement and compliance with this 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, 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. 2. Each party will exchange a fully signed executed copy or original of this Agreement. Defendant cannot proceed with processing payment without a fully executed copy of the Agreement from Plaintiff. 3. 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 Forty Thousand Dollars ($40,000.00) made payable to "MA RAMIREZ AND LAW OFFICES OF GENE GOLDSMAN." This amount represents a full and complete settlement of Plaintiffs claims for all damages alleged in the Action. The City of Santa Ana will file the Request for Dismissal following receipt of the foregoing check by Plaintiffs counsel. 4. Plaintiff and Defendant agree that this Agreement constitutes full and complete settlement of all claims 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. 5. Plaintiff acknowledges and agrees that Defendant has made no representations regarding the tax consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that she and she alone is liable for all taxes, if any, which are owed by heron any amount Pagel of 4