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VARGAS, LAURA SAUCEDA
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VARGAS, LAURA SAUCEDA
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Last modified
6/23/2014 11:27:44 AM
Creation date
6/23/2014 9:33:56 AM
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Contracts
Company Name
VARGAS, LAURA SAUCEDA
Contract #
A-2014-079
Agency
City Attorney's Office
Council Approval Date
2/4/2014
Destruction Year
0
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Fiom: Mash Kazeiouni Fax: (949) 407 -6721 To Fax: +1 (714) 6693033 Page 6 of '120212712014 1047 <br />1. Laura Sauceda: $2000,00 for property damage portion and $3000.00 for PI <br />Portion: Total $5000.00 <br />2. Josefina Vargas: $3000.00 for PI Portion: Total $3000.00 <br />3. Oscar Moreno, a minor by and through his guardian ad litem, Laura Sauceda <br />Vargas: $2000 for PI Portion: Total $2000,00- <br />4. Jasmine Moreno, a minor by and through her guardian ad litem, Laura <br />Sauceda: $2000 for PI Portion: Total $2000.00 <br />(b) Plaintiffs will sign a Request for Dismissal of the Entire Action with <br />Prejudice form dismissing Case No. 30- 2014- 00697500 -CU -PA -CJC as to Defendant, CITY OF <br />SANTA ANA, in its entirety, <br />(c) Plaintiffs and Defendant CITY OF SANTA ANA agree that the <br />foregoing mutual dismissals constitute full and complete settlement of all claims made against all <br />parties in this litigation. Plaintiffs will not seek any father compensation for any other claimed <br />damage, costs, or attorney's fees in connection with the matters encompassed in this Agreement. <br />(d) Plaintiffs acknowledge and agree that the Defendant has made no <br />representations to them regarding the tax consequences of any amounts received by them <br />pursuant to this Agreement. Plaintiffs agree that they and they alone are liable for all taxes, if <br />any, which are owed by them on any amount received hereunder including interest and penalties. <br />Plaintiffs will hold the Defendant harmless from any and all claims made by federal, state, or <br />local taxing authorities or lien holders against Plaintiffs on amounts owed by tbcm. <br />(e) Plaintiff, Laura Sauceda Vargas as Guardian ad Litem for Plaintiffs <br />Oscar Moreno, a minor and Jasmine Moreno, a minor, will provide a Release to the City of Santa <br />Ana pursuant to Probate Code §3401( c)(2) for the mhrors, <br />THIRD: Plaintiffs represent that, with the exception of Case No. 30-2014 - <br />00697500-CU-PA- CJC they have not filed any complaints, claims, or actions against Defendant <br />including any of its officers, agents, directors, supervisors, employees, or representatives of <br />CITY OF SANTA ANA with any state, federal, or local agency or court and that she will not do <br />so at any time hereafter as it relates to this action and that if any agency or court assumes <br />jurisdiction of any complaint, claim, or action against the Defendant on Plaintiffs' behalf, <br />Plaintiffs will direct that agency or court to withdraw and dismiss with prejudice the matter. <br />FOURTH: Plaintiffs represent and warrants that no portion of any claim, right, <br />demand, action or cause of action that they have or might have against Defendant and any <br />
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