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A-2013-063 SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS r This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made and entered into by and between JOSE RUMBO (hereinafter referred to as "Plaintiff'), and OFFICER J. CORREAL (hereinafter "Defendant"). ? WITNESSETH: WHEREAS, Plaintiff filed an action against Defendant, OFFICER J. CORREAL, in Orange County Superior Court bearing case number 30-2012-00559685 which was removed to ct the United States District Court for the Central District of California entitled JOSE RUMBO v. OFFICER J. CORREAL, et al. Case No. SACV12-00806-FMO (MLGx) (the "Action"). s WHEREAS, Plaintiff and the Defendant 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: FIRST: This Agreement and compliance with this Agreement shall not be construed as an admission by and of the Defendant and of any liability whatsoever, or as an admission by Defendant of any violation of the rights of Plaintiff or any person, violation of any order, law, statute, duty, or contract whatsoever against Plaintiff or any person. Defendant specifically disclaims any liability to Plaintiff or any other person for any alleged violation of the rights of Plaintiff or any person, or for any alleged violation of any order, law, statute, duty, or contract on the part of any employees, agents of the CITY OF SANTA ANA. Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. SECOND: (a) Plaintiff will sign a Stipulation to Dismiss the Entire Action with Prejudice dismissing Case No. SACV12-00806-FMO (MLGx) as to Defendant, OFFICER J. CORREAL, in its entirety. (b) At the time Plaintiff delivers to counsel for Defendant a fully signed original of this Agreement, and a signed Stipulation to Dismiss, Defendant will deliver to Plaintiffs counsel, a check in the total sum of SEVENTY THOUSAND DOLLARS ($70,000.00) in full and complete settlement of all claims made against Officer J. Correal in this litigation. The check is to be made out to "LAW OFFICES OF MICHAEL A. LOTTA AND JOSE RUMBO." This amount is in full and complete settlement for Plaintiffs claims for all damages alleged in the above-referenced Complaint.