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(c) Plaintiff, JOSE RUMBO, and Defendant, OFFICER J. CORREAL,
<br />agree that the foregoing mutual dismissals constitute full and complete settlement of all claims
<br />made against all parties in this litigation. Plaintiff will not seek any further compensation for any
<br />other claimed damage, costs, or attorney's fees in connection with the matters encompassed in
<br />this Agreement.
<br />(d) Plaintiff acknowledges and agrees that the Defendant has made no
<br />representations to him regarding the tax consequences of any amounts received by him pursuant
<br />to this Agreement. Plaintiff agrees that he and he alone is liable for all taxes, if any, which are
<br />owed by him on any amount received hereunder including interest and penalties. Plaintiff will
<br />hold the Defendant harmless from any and all claims made by federal, state, or local taxing
<br />authorities or lien holders against Plaintiff on amounts owed by him.
<br />THIRD: Plaintiff represents that, with the exception of Case No. SACV 12-
<br />00806-FMO (MLGx) he has not filed any complaints, claims, or actions against Defendant,
<br />OFFICER J. CORREAL, including any of his officers, agents, directors, supervisors, employees,
<br />or representatives with any state, federal, or local agency or court and that he will not do so at
<br />any time hereafter as it relates to this action and that if any agency or court assumes jurisdiction
<br />of any complaint, claim, or action against the Defendant on Plaintiff's behalf, Plaintiff will direct
<br />that agency or court to withdraw and dismiss with prejudice the matter.
<br />FOURTH: Plaintiff represents and warrants that no portion of any claim, right,
<br />demand, action or cause of action that he has or might have against Defendant, OFFICER J.
<br />CORREAL, and any officers, agents, directors, supervisors, employees, or representatives or any
<br />portion of any recovery or settlement to which he may be entitled from Defendant, has been
<br />assigned or transferred to any person, entity or corporation in any manner, including by way of
<br />subrogation, transfer or operation of law. In the event that any claim, demand, suit or lien has or
<br />should have been made were instituted against the Defendant including the officers, agents,
<br />directors, supervisors, employees, or representatives because of any such purported assigmnent,
<br />subrogation, transfer or lien, Plaintiff agrees to indemnify and hold harmless Defendant and his
<br />officers, agents, directors, supervisors, employees, or representatives against any such claim,
<br />suit, demand, and to pay and satisfy any such claim, suit, demand or lien, including expenses of
<br />investigation, attorney's fees and costs.
<br />FIFTH: The parties hereto hereby agree that all rights under Section 1542 of the Civil
<br />Code of the State of California are hereby waived. Civil Code Section 1542 provides as follows:
<br />"A general release does not extend to claims which the creditor does not
<br />know or suspect to exist in his favor at the time of executing the release,
<br />which if known by him must have materially affected his settlement with the
<br />debtor."
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