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THORN, JODI
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THORN, JODI
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Last modified
10/13/2025 1:12:51 PM
Creation date
10/13/2025 1:12:46 PM
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Contracts
Company Name
THORN, JODI
Contract #
A-2025-163
Agency
City Attorney's Office
Council Approval Date
9/16/2025
Expiration Date
1/1/1900
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Docusign Envelope ID:2818CA41-5lF2-4508-AD4E-E22080A42E9A A-2025-163 <br /> INSUWCE NOT REQUIRED <br /> 'WfORK IVIRY PROCEED <br /> CITY CURK <br /> DATE: OCT 13 2015 <br /> a: SETTLEMENT AGREEMENT AND <br /> CAO(a) <br /> JOYm4'hon 9 TierkevrstJ RELEASE OF ALL CLAIMS <br /> 9aisu�Hernc+nd6z(pz) <br /> This Settlement Agreement and Release of All Claims ("Agreement") is made and entered into <br /> by and between JODI THORN ("Plaintiff'), and CITY OF SANTA ANA and CRISTAL GUTIERREZ <br /> (collectively, "Defendants"). <br /> WITNESSETH: <br /> WHEREAS, Plaintiff filed an action against Defendants in the Superior Court of the State <br /> California,County of Orange,Central Justice Center known as JODI THORN v. CITY OF SANTA ANA, <br /> et al., Case No. 30-2024-01380358-CU-PA-CJC (the "Action"). <br /> WHEREAS, Plaintiff and Defendants (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 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 Plaintiff or any person,violation of any order, law, statute,duty,or contract <br /> whatsoever against Plaintiff or any person. Defendants specifically disclaim any liability to Plaintiff <br /> or any other person for any alleged violation of the rights of Plaintiff or any person, or for any alleged <br /> violation of any order, law, statute, duty, or contract on the part of any employees or agents of <br /> Defendants. Likewise, this Agreement and compliance with this Agreement shall not be construed as an <br /> admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. <br /> 2. Each party will exchange a fully signed executed copy or original of this Agreement. <br /> Defendants cannot proceed with processing payment without a fully executed copy of the Agreement <br /> from Plaintiff. <br /> 3. Following receipt of, or in exchange for, an executed copy of a Request for Dismissal <br /> form from Plaintiff dismissing this Action with prejudice, Defendants will make available a check in <br /> the amount of One Hundred Thirty-Five Thousand Dollars($I50,000.00) made payable "JODI THORN <br /> AND RIZIO LIPINSKY HEITING,PC". This amount represents a full and complete settlement of <br /> Plaintiffs claims for all damages alleged in the Action. The City of Santa Ana will file the Request for <br /> Dismissal following receipt of the foregoing check by Plaintiffs counsel. <br /> 4. Plaintiff and Defendants agree that this Agreement constitutes full and complete <br /> settlement of all claims made against Defendants in this Action. Plaintiff will not seek any further <br /> compensation for any other claimed damages, costs, or attorney's fees in connection with the matters <br /> encompassed in this Agreement. <br /> 5. Plaintiff acknowledges and agrees that Defendants have made no representations <br /> Page I of 4 <br />
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