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A-2025-051 INSURANCE NOT REQUIRED WORK NIU PROCEED p! LM QPI CITY CLERK ,x4ra H flar&I DATE: MAY 7 2025 ,palrc� I,nPu o fA�Ai} SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS .I I+I��: �� . i�� I I I:I � I1 I I ! � II � � it �1I1I1 � lnt Agr > i pIe se'of All Cla' s ('Agreemen s made and entered) into by ;e[-�ee T ESFO I ME OZA DE ASCENSION' d MATIL E ASCENCIO DE JUAREZ (col,ectively, la` tiffs"), 1 and CITY OF SANTA A and DA ANGEL (collectively, "Defendants") 181!:III•A�I II ' I I I' i:!' I4 � I I it II ! ! , WITNESSETH: WHEREAS,Plaintiffs filed an action against Defendants in the Superior Court of the State California,County of Orange,Central Justice Center District known as TELESFORA MENDOZA DE ASCENSION et al. v.DAVID ANGEL.,et al. Case No. 30-2024-01371513-CU-PA-CJC(the"Action"). WHEREAS, Plaintiffs and Defendants (collectively, the "Parties"),desire to settle fully and finally all differences between them, including, but in no way limited to,those differences described above. 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 Defendants of any liability whatsoever, or as an admission by Defendants of any violation of the rights of Plaintiffs or any person,violation of any order,law,statute,duty,or contract whatsoever against Plaintiffs or any person. Defendants specifically disclaim any liability to Plaintiffs or any other person for any alleged violation of the rights of Plaintiffs 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 Defendants. Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiffs of any liability,misconduct,or wrongdoing whatsoever. 2. Each party will exchange a fully signed executed copy or original of this Agreement. Defendants cannot proceed with processing payment without a fully executed copy of the Agreement from Plaintiffs. 3. Following receipt of, or in exchange for, an executed copy of a Request for Dismissal form from Plaintiffs dismissing this Action with prejudice,Defendants will make available two checks that total One Hundred Thirty-Eight Thousand Dollars ($138,000.00). One check will be made payable to"TELESFORA MENDOZA DE ASCENSION AND LAW OFFICE OF WILLIAM L. PAULSEN& ASSOCIATES"in the amount of$67,000. The second check will be made payable to"MATILDE ASCENCIO DE JUAREZ AND LAW OFFICE OF WILLIAM L. PAULSEN&ASSOCIATES "in the amount of$71,000.These amounts represent a full and complete settlement of Plaintiff's'claims for all damages alleged in the Action. The City of Santa Ana will file the Request for Dismissal following receipt of the foregoing checks by Plaintiffs'counsel. 4. Plaintiffs and Defendants agree that this Agreement constitutes frill and complete settlement of all claims made against Defendants in this Action. Plaintiffs will not seek any further Page 1 of 4