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A-2025-020 <br />MAR 0 71015 <br />p'.Ghotd% <br />SETTLEMENT AGREEMENT AND <br />SPECIFIC RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release of All Claims ("Agreement') dated March 4, 2025 is <br />made and entered into by and between SANTA ANA POLICE OFFICERS ASSOCIATION <br />("Plaintiff), and CITY OF SANTA ANA ("Defendant'). <br />WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State <br />California, County of Orange, Central Justice Center known as SANTA ANA POLICE OFFICERS <br />ASSOCIATION, et al. v. CITY OF SANTAANA, or al., Case No. 30-2021-01230129 (the "Action"). <br />WHEREAS, Plaintiff and Defendant (collectively, the "Parties"), desire to settle fully and <br />finally all differences between them, including, but in no way limited to, those differences described <br />above. <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 to <br />avoid unnecessary litigation, it is hereby agreed by and between the Patties as follows: <br />1. This Agreement and compliance with this Agreement shall not be construed as an <br />admission by Defendant of any liability whatsoever, or as an admission by Defendant of any violation <br />of the rights ofPlaintiff or any person, violation of any order, law, statute, duty, or contract whatsoever <br />against Plaintiff or any person. Defendant specifically disclaims any liability to Plaintiff or any other <br />person for any alleged violation of the rights of Plaintiff or any person, or for any alleged violation of any <br />order, law, statute, duty, or contract on the part of any employees or agents of Defendant. Likewise, this <br />Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiff of <br />any liability, misconduct, or wrongdoing whatsoever. <br />2. Each party will exchange a fully signed executed copy or original of this Agreement. <br />3. Following receipt of, or in exchange for, an executed copy of a Request for Dismissal <br />form from Plaintiff dismissing all claims made by Plaintiff in this Action with prejudice, Defendant <br />will return to Plaintiff check # 36570 in the amount of $10,040.00 from Plaintiff for payment of sanctions <br />in the Action pursuant to Court order dated Deccmbor 18, 2024 and will file the Request for Dismissal with <br />the Court. <br />4. Plaintiff and Defendant agree that this Agreement constitutes full and complete <br />settlement of all claims made by Plaintiff against Defendant in this Action. Plaintiff and Defendant <br />will not seek any further compensation for any other claimed damages, costs, or attorney's fees in <br />connection with the matters encompassed in this Agreement. <br />5. Plaintiff acknowledges and agrees that Defendant has made no representations regarding <br />the tax consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that it and <br />it alone is liable for all taxes, if any, which are owed by it on any amount received hereunder including <br />interest and penalties. Plaintiff will hold Defendant harmless from any and all claims made by federal, <br />Page 1 of 4 <br />