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Q ". C A0 M N-2016-040 <br />n��� -a, ��,,pp SETTLEMENT AGREEMENT <br />k4 kl1c��Cf 7 AND RELEASE OF ALL CLAIMS <br />4 4 20v This Settlement Agreement and Release of All Claims (hereinafter "Agreement") <br />is made and entered into by and between SUPERIOR COURT OF THE STATE OF <br />CALIFORNIA COUNTY OF ORANGE (hereinafter referred to as "Plaintiff"), and the <br />CITY OF SANTA ANA, (hereinafter "Defendant"). <br />WITNESSETH: <br />WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of <br />the State of California, County of Orange, Central Justice Center District, case number <br />30-2009-99123214. Venue was transferred to the Los Angeles County Superior Court <br />West District Santa Monica, CA known as SUPERIOR COURT OF THE STATE OF <br />CALIFORNIA COUNTY OF ORANGE v. CITY OF SANTA ANA, et al. Case No. 123214 <br />(the "Action") <br />WHEREAS, Plaintiff and the Defendant desire to settle fully and finally all <br />differences between them, including, but in no way limited to, those differences <br />described above. <br />NOW, THEREFORE, in consideration of the mutual covenants and promises <br />herein contained and other good and valuable consideration, receipt of which is hereby <br />acknowledged, and to avoid unnecessary litigation, it is hereby agreed by and between <br />the parties as follows: <br />FIRST: This Agreement and compliance with this Agreement shall not be <br />construed as an admission of liability by the Defendant whatsoever, or as an admission <br />by the Defendant of any violation of the rights of Plaintiff or any person, or a violation of <br />any order, law, statute, duty, or contract whatsoever against Plaintiff or any person. The <br />Defendant specifically disclaims any liability to Plaintiff or any other person for any <br />alleged violation of the rights of Plaintiff or any person, or for any alleged violation of <br />any order, law, statute, duty, or contract on the part of any employees or agents of the <br />City of Santa Ana. Likewise, this Agreement and compliance with this Agreement shall <br />not be construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing <br />whatsoever. <br />SECOND: (a) Plaintiff's attorney will sign a Request for Dismissal form <br />dismissing with prejudice, Defendant, CITY OF SANTA ANA only. <br />1 <br />