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(b) Defendant will notify Plaintiff's attorney when the settlement <br />check is ready. Thereafter, Plaintiff s attorney will send. Defendant a fully signed copy of <br />this Agreement, and an executed original Request for Dismissal form as to this Defendant <br />only. In turn, the Defendant will send via overnight mail to Plaintiffs counsel, a check in <br />the amount of TWENTY-FIVE THOUSAND DOLLARS AND ZERO CENTS <br />($25,000.00) in full and complete settlement of all claims made against the City of Santa <br />Ana in this litigation. Alternatively, Plaintiff's attorney can pick up the check in person. <br />The check will be made payable to "Judicial Council of California c/o AIMS and Law <br />Offices of Lily Chow." This amount is in full and complete settlement for Plaintiff's <br />claims for all damages alleged in the above -entitled action against this Defendant. <br />(c) Plaintiff hereby acknowledges that the settlement check is made <br />payable to an entity not specifically identified as a Plaintiff in the Action. <br />(d) Plaintiff agrees that the foregoing dismissal constitutes full and <br />complete settlement of all claims made by Plaintiff as to this Defendant related to or <br />arising from this litigation. Plaintiff will not seek any further compensation for any other <br />claimed damage, costs, or attorney's fees in connection with the matters encompassed in <br />this Agreement from this Defendant. <br />(e) Plaintiff acknowledges and agrees that the Defendant has made <br />no representations regarding tax consequences of any amounts received pursuant to this <br />Agreement. Plaintiff agrees that it is liable for all taxes, if any, which are owed by it on <br />any amount received hereunder including interest and penalties. Plaintiff will hold the <br />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 it. <br />THIRD: Plaintiff represents that, with the exception of Case No. 123214 it <br />has not filed any complaints, claims, or actions against Defendant including any of its <br />officers, agents, directors, supervisors, employees, or representatives of the City of Santa <br />Ana with any state, federal, or local agency or court and that she will not do so at any <br />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 />Plaintiff will direct that agency or court to withdraw and dismiss with prejudice the <br />matter. <br />FOURTH: Plaintiff represents and warrants that no portion of any claim, <br />right, demand, action or cause of action against Defendant and any officers, agents, <br />directors, supervisors, employees, or representatives of the City of Santa Ana or any <br />portion of any recovery or settlement to which she may be entitled from Defendant, has <br />been assigned or transferred to any person, entity or corporation in any manner, including <br />2 <br />