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Docusign Envelope ID: 32750424-8211-46D5-9003-858914871428 N-2025-006
<br />JAN 15 2025
<br />0 CAO(d)
<br />SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS
<br />This Settlement Agreement and Release of All Claims ("Agreement") is made and entered into by
<br />and between John W. Yentes ("Plaintiff') and the City of Santa Ana ("City" and/or "Defendant").
<br />WHEREAS, Plaintiff filed an action against the City and Defendant, Eden Jonathan Peralta, in the
<br />Superior Court of the State California, County of Orange, Central Justice Center known as JOHN W.
<br />YENTES v. CITY OF SANTA ANA Case No. 30-2024-01379803-CU-PO-NJC (the "Action").
<br />Collectively, the City and Peralta are referred to as "Defendants" hereafter.
<br />WHEREAS, Plaintiff and Defendants (collectively, the "Parties"), desire to settle fully and finally
<br />all differences between them, including, but in no way limited to, those differences described above.
<br />This Agreement hereby documents a settlement and/or release of all issues arising from the Action.
<br />NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained
<br />and other good and valuable consideration, receipt of which is hereby acknowledged, and to avoid
<br />unnecessary litigation, it is hereby agreed as follows:
<br />1. This Agreement and compliance with this Agreement shall not be construed as an admission
<br />by the Defendants of any liability whatsoever, or as an admission by the Defendants of any violation
<br />of the rights of Plaintiff or any person, violation of any order, law, statute, duty, or contract
<br />whatsoever against Plaintiff or any person. The Defendants specifically disclaim any liability to
<br />Plaintiff or any other person for any alleged violation of the rights of Plaintiff or any person, or for
<br />any alleged violation of any order, law, statute, duty, or contract on the part of any employees or
<br />agents of the City or Defendant Peralta. Likewise, this Agreement and compliance with this
<br />Agreement shall not be construed as an admission by Plaintiff of any liability, misconduct, or
<br />wrongdoing whatsoever.
<br />2. Each party will exchange a fully signed executed copy, or original, of this Agreement. The
<br />City cannot proceed with processing payment as outlined below without a fully executed copy of the
<br />Agreement from Plaintiff.
<br />3. Following the City's receipt of an executed Request for Dismissal with prejudice of the
<br />entire Action from Plaintiff, the City will make available to Plaintiff a check in the amount of
<br />Forty -Seven Thousand Five Hundred Dollars and no cents ($47,500) made payable to "JOHN W.
<br />YENTES and FORRESTER LOPEZ APC."
<br />4. For consideration of the sum of Twenty -Five Thousand Dollars and No Cents ($25,000.00), paid by
<br />draft issued by State Faun, Plaintiff John Yentes, on behalf of themselves and their dependents, heirs,
<br />executors, administrators, and assigns, hereby fully and forever release and discharge Eden Jonathan
<br />Peralta, and each of their partners, employees, agents, personal representatives, insurers, attorneys,
<br />successors or predecessors in interest, assigns, and subsidiaries, past and present, and any other person or
<br />organization, who is or might be liable as a result of Eden Jonathan Peralta's alleged negligence on or
<br />about June 11, 2023, from any and all claims, demands, liens, agreements, contracts, covenants, actions,
<br />suits, causes of action, obligations, controversies, debts, costs, attorney fees, expenses, damages,
<br />judgments, orders, and liabilities of whatever kind and nature in law, equity, or otherwise, whether known
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<br />December 27, 2024
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