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[�IA;Y A-2026-088 L{_r� vLC_f\'K I)A L: JUN 2 4 7076 0 6A0(tR) 0-0 SETTLEMENT AGREEMENT AND MUTUAL RELEASE This Settlement Agreement and Mutual Release ("Agreement") is made and entered into by and between Judith Valdez ("Valdez") and the City of Santa Ana(the"City") (collectively the "Parties"). In consideration for the execution of this Agreement, and the performance of the terms and conditions set forth herein,the Parties agree as follows. A. Whereas,Valdez filed lawsuits against the City based on (1) allegations concerning Valdez's employment with the City in the action captioned Judith Valdez v. City of Santa Ana, Orange County Superior Court, Case No. 30-2023-01359457-CU-OE-NJC and (2) allegations concerning personal injuries Valdez incurred during her employment with the City in the action captioned Jorge Arroyo, et al.v. City of Santa Ana, Orange County Superior Court, Case No. 30-2025-01492970-CU-PO-CJC (collectively,the"Actions"); B. Whereas,the City denies, and continues to deny Valdez's claims in the Actions and denies any other wrongful or unlawful conduct, claim, damage,or liability of any kind; C. Whereas,the Parties desire to reach a full and final settlement and resolution of all claims, controversies, and disputes that Valdez has or may have against the Released Parties (as defined below); D. Whereas,the Parties desire to reach a full and final settlement and resolution of all claims, controversies, and disputes that the City has or may have against Valdez; E. NOW THEREFORE, in consideration for the execution of this Agreement and the performance of the terms and conditions herein, and without admission of liability,the Parties agree as follows: 1. Consideration. In consideration for the execution of this Agreement, and the performance of the terms and conditions set forth herein,the Parties hereby agree as follows: a. Settlement Payment. Subject to the performance of the terms and conditions set forth herein,the City will pay Valdez the total amount of Nine Hundred Fifty Thousand($950,000), less applicable withholdings as set forth below ("Settlement Payment"). The Settlement Payment will be made in two checks: (1) one check for alleged but disputed lost wages made payable to Valdez in the amount of Ten Thousand Dollars ($10,000), less applicable withholdings,to be reported on a Form W-2; and (2) one check for alleged but disputed personal injury damages, attorneys'fees,and costs made payable to Elite Trial Group Law Firm Trust Account in the amount of Nine Hundred Forty Thousand Dollars ($940,000), subject to the issuance of an IRS Form 1099. The Settlement Payment will be provided to Elite Trial Group Law Firm, 30950 Rancho Viejo Road, Suite 22613, San Juan Capistrano,CA 92675, via wire- transfer or FedEx Overnight Delivery (and the City shall inform Valdez's counsel in writing beforehand of the exact date of the wire-transfer or overnight delivery),within Twenty-Three (23)calendar days after the Effective Date of this Agreement(as defined below). a. Good and Valuable Consideration. The Parties expressly agree that the consideration set forth in this Section 1 constitutes good and valuable consideration in addition to 4935- 33-886.1 1 of 9 JV ity's Initials Valdez's Initials