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(c) Plaintiff, ANTHONY SILVA, and Defendants, CITY OF SANTA <br />ANA and EUGENIO SANCHEZ, agree that the foregoing mutual dismissals constitute fall and <br />complete settlement of all claims made against all parties in this litigation. Plaintiff will not seek <br />any farther compensation for any other claimed damage, costs, or attorney's fees in connection <br />with the matters encompassed in this Agreement. <br />(d) Plaintiff acknowledges and agrees that the Defendants had made no <br />representations regarding the tax consequences of any amounts received pursuant to this <br />Agreement. Plaintiff agrees that he and he alone is liable for all taxes, if any, which are owed by <br />him on any amount received hereunder, including interest and penalties. Plaintiff will hold the <br />Defendants harmless from any and all claims made by federal, state, or local taxing authorities or <br />lien holders against Plaintiff on amounts owed by him. <br />THIRD: Plaintiff represents that, with the exception of Case No. 30- 2012 - 00596622 and <br />the government tort claim associated therewith, he has not filed any complaints, claims, or <br />actions against Defendants including any of its officers, agents, directors, supervisors, <br />employees, or representatives of CITY OF SANTA ANA with any state, federal, or local agency <br />or court and that they will not do so at any time hereafter as it relates to this action and that if any <br />agency or court assumes jurisdiction of any complaint, claim, or action against the Defendants on <br />Plaintiffs behalf, Plaintiff will direct that agency or court to withdraw and dismiss with <br />prejudice the matter. <br />FOURTH: The parties hereto hereby agree that all rights under Section 1542 of the <br />Civil Code of the State of California are hereby waived. Civil Code Section 1542 provides as <br />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." <br />FIFTH: Notwithstanding the provisions of Civil Code section 1542, each party hereby <br />irrevocably and unconditionally releases and forever discharges each other party and each and all <br />of its officers, agents, directors, supervisors, employees, representatives, and its successors and <br />assigns and all persons acting by, through, under, or in concert with each other party from any <br />and all charges, complaints, claims, and liabilities of any kind or nature whatsoever, known or <br />unknown, suspected or unsuspected (hereinafter referred to as "claim" or "claims ") which each <br />releasing party at any time heretofore had or claimed to have or which each releasing party at <br />any time hereafter may have or claim to have, incidental to the incident(s) which form the basis <br />of this lawsuit. <br />