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N-2024-227 0- 1 "" D'.Gpro� 4) FA�`Pt) CoJrf- SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims("Agreement") is made and entered into by and between Gloria Herrera("Plaintiff')and the City of Santa Ana("City"and/or"Defendant"). WITNESSETH: WHEREAS,Plaintiff filed an action against Defendant in the Superior Court of the State California, County of Orange, Central Justice Center District known as GLORIA HERRERA v. CITY OF SANTA ANA and DOES 1 to 100, inclusive Case No. 30-2022- 01253031-CU-PO-CJC (the "Action"). Plaintiff later named individual, Elena Verdugo, as a defendant("Verdugo"). The City and Verdugo filed cross-complaints against each other. 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. This Agreement hereby documents a settlement between the Parties of all issues arising from 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 the City's receipt of an executed Request for Dismissal with prejudice of the entire Action from Plaintiff,the City will make available to Plaintiff a check in the amount of Twenty-Five Thousand Dollars and no cents($25,000)made payable to"SEDAGHAT LAW GROUP CLIENT TRUST FOR THE BENEFIT OF GLORIA HERRERA." 4. The foregoing amount to be paid by Defendant represents the Defendant's full and complete settlement of Plaintiff's claims for all damages alleged in the Action. The City will file the Request for Dismissal following confirmation that counsel for Plaintiff has received the check from Defendant and has received any monies due to Plaintiff by Verdugo. 5. 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 Page 1 of 4