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,Ul 1 i0j N-2024-228 Csa A/a SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims("Agreement")is made and entered into by and between the City of Santa Ana("City"), and Elena Verdugo("Verdugo"). Collectively, the City and Verdugo are referred to as"Defendants"hereafter. WITNESSETH: WHEREAS,Plaintiff,Gloria Herrera("Plaintiff') filed an action against the City in the Superior Court of the State California,County of Orange, Central Justice Center 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 Verdugo as a defendant. Thereafter,the City and Verdugo filed cross-actions. WHEREAS, the City and Verdugo(collectively, the "Parties"),desire to settle fully and finally all differences between them, including,but in no way limited to, those differences described above with a sole exception as outlined below in paragraph 5. This Agreement hereby documents a settlement between the Parties. 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 either the City or Verdugo of any liability whatsoever, or as an admission by the City and/or Verdugo of any violation of the rights of any person,violation of any order, law, statute, duty, or contract whatsoever against Plaintiff or any person.Both the City and Verdugo specifically disclaim any liability to Plaintiff or each other 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 the City and/or Verdugo. 2_ Each party will exchange a fully signed executed copy,or original,of this Agreement. 3. Upon receipt of a fully-executed copy of this Agreement,each party will file a Request for Dismissal with prejudice of their respective cross-complaint filed in this Action. 4. Neither the City nor Verdugo has agreed to pay the other any monies in consideration of dismissing their respective cross-complaint. Rather, the consideration for entering into this Agreement is the payment of monies to Plaintiff in sums that are subject to separate agreements entered into by the City and Verdugo with Plaintiff and as memorialized therein and for a dismissal of the entire action by Plaintiff The City and Verdugo specifically acknowledge that the Plaintiff, the City and Verdugo have collectively entered into a global settlement of the Action although the settlements are documented in individual agreements by and between the Plaintiff and each defendant identified hereto. 5. The City and Verdugo agree that this Agreement constitutes full and complete settlement of all claims made by and between the City and Verdugo in their respective cross-complaints filed in this Action_ Both the City and Verdugo agree to dismiss their respective cross-complaints with Page 1 of 4