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AUG 0 8 2024
<br />N-2024-267
<br />SETTLEMENT AGREEMENT
<br />AND RELEASE OF ALL CLAIMS
<br />C&AWCA V� (AMS)
<br />This Settlement Agreement and Release of All Claims ("Agreement") is made and entered
<br />into by and between ROGELIO REYES and LORENA REYES (sometimes collectively,
<br />"Plaintiffs") and CITY OF SANTA ANA, KAMERON HENDERSON, MATTHEW D.
<br />WHARTON, DAVID GUZMAN, JUSTIN L. COLLINS, JONATHON PEREZ, ANH TU S.
<br />PHAN, KENNETH GRAY, and DANIEL CARRILLO (sometimes collectively "Defendants").
<br />WIT NE S SETH:
<br />WHEREAS, Plaintiff ROGELIO REYES filed an action against Defendants in the
<br />Superior Court of the State California, County of Orange, Central Justice Center styled Rogelio
<br />Reyes v. City ofSantaAna, et al., Case No. 30-2021-01218405-CU-CR-CJC (the "Rogetio Reyes
<br />Action").
<br />WHEREAS, Plaintiff LORENA REYES filed an action against Defendants in the United
<br />States District Court for the Central District of California styled Lorena Reyes v. City of Santa
<br />Ana, et al., Case No. 8:20-cv-00071 -DOC-AD S (the "Lorena Reyes Action").
<br />WHEREAS,, Plaintiffs and Defendants (collectively, the "Parties"), desire to settle fully
<br />and finally all differences between them, including, but in no way limited to, those differences
<br />described in the Rogello Reyes Action and the Lorena Reyes Action (collectively, the "Actions").
<br />NOW, THEREFORE, in consideration of the mutual covenants and promises herein
<br />contained and other good and valuable consideration, receipt of which is hereby acknowledged, and
<br />to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows:
<br />I . This Agreement and compliance with this Agreement shall not be construed as an
<br />admission by Defendants of any liability whatsoever, or as an admission by Defendants of any
<br />violation of the rights of Plaintiffs or any person, violation of any order, law, statute, duty, or contract
<br />whatsoever against Plaintiffs or any person. Defendants specifically disclaim any liability to
<br />Plaintiffs or any other person for any alleged violation of the rights of Plaintiffs or any person, or
<br />for any alleged violation of any order, law, statute, duty, or contract on the part of any employees
<br />or agents of Defendants. Likewise, this Agreement and compliance with this Agreement shall not
<br />be construed as an admission by Plaintiffs of any liability, misconduct, or wrongdoing whatsoever.
<br />2. Each party will exchange a fully signed executed copy or original of this
<br />Agreement. Defendants cannot proceed with processing payment without a fully executed copy of
<br />the Agreement from Plaintiffs.
<br />3. Following receipt of, or in exchange for, an executed copy of Request for Dismissal
<br />forms from Plaintiffs dismissing the Actions against Defendants with prejudice, Defendant City
<br />of Santa Ana will make available a check in the amount of Ten Thousand Dollars ($10,000.00)
<br />made payable to "Law Office of Jerry L. Steering, Attorney Client Trust Account." This amount
<br />represents a full and complete settlement of Plaintiffs' claims for all damages alleged in the Actions.
<br />Defendant City of Santa Ana will file the Requests for Dismissal following receipt of the foregoing check
<br />by Plaintiffs' counsel.
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