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any other claimed damages, costs, or attorneys fees in connection with the matters encompassed in
<br /> this Agreement.
<br /> 6. Plaintiff acknowledges and agrees that the City has made no representations regarding the tax
<br /> consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that she and she
<br /> alone is liable for all taxes, if any, which are owed by her on any amount received hereunder including
<br /> interest and penalties. Plaintiff will hold the City harmless from any and all claims made by federal, state,
<br /> or local taxing authorities.
<br /> 7. Plaintiff will hold the City harmless from any and all lien holders of any kind, specifically liens for
<br /> medical care or medical expenses, owed to insurance companies, Medi-Care or Medi-Cal, or any other
<br /> medical providers, to whom Plaintiff is indebted. Plaintiff further acknowledges that she and not the City
<br /> is responsible for compromising any liens related to, or arising from,this Action.
<br /> GCH (Plaintiff's Initials)
<br /> 8. Plaintiff represents that, with the exception of this Action and the government tort claim
<br /> associated therewith and submitted to the City of Santa Ana, she has not filed any complaints,
<br /> claims, or actions against Defendant including any of its officers, agents, directors, supervisors,
<br /> employees, or representatives of Defendant with any state, federal, or local agency or court and that
<br /> she will not do so at any time hereafter as it relates to this Action and that if any agency or court
<br /> assumes jurisdiction of any complaint, claim, or action against Defendant on Plaintiffs behalf,
<br /> Plaintiff will direct that agency or court to withdraw and dismiss the matter with prejudice.
<br /> 9. The Parties hereto hereby agree that all rights under Section 1542 of the Civil Code of the
<br /> State of California are hereby waived. Civil Code Section 1542 provides as follows:
<br /> "A general release does not extend to claims which the creditor does
<br /> not know or suspect to exist in his or her favor at the time of executing
<br /> the release,which if known by him or her must have materially
<br /> affected his or her settlement with the debtor."
<br /> 10. Notwithstanding the provisions of Civil Code section 1542, each party hereby irrevocably
<br /> and unconditionally releases and forever discharges each other party and each and all of its officers,
<br /> agents, directors, supervisors, employees, representatives, insurance companies, any subsidiaries or
<br /> affiliates of said insurance companies, attorneys, successors and assigns and all persons acting by,
<br /> through, under, or in concert with each other party from any and all charges, complaints, claims, and
<br /> liabilities of any kind or nature whatsoever, known or unknown, suspected or unsuspected
<br /> (hereinafter referred to as"claim"or"claims") which each releasing party at any time heretofore
<br /> had or claimed to have or which each releasing party at any time hereafter may have or claim to
<br /> have, incidental to the incident(s)which form the basis of the Action.
<br /> 11. Each person signing below represents that he/she has reviewed all aspects of this
<br /> Agreement,that the Agreement has been carefully read and fully explained to them and that they
<br /> understand every provision of this Agreement,that they understand that in agreeing to this
<br /> document they are releasing each party hereby from any and all claims they may have against each
<br /> party released, that they voluntarily agree to all the terms set forth in this Agreement, that they
<br /> knowingly and willingly intend to be legally bound by the same, that they were given the
<br /> opportunity to consider the terms of this Agreement and discussed them with legal counsel. Each
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