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APR -5 -20316 92:21P PROM:NUNLEY BUSINESS 7148843846 T0:1562624117B
<br />SETTLEMENT AGREEMENT AND RELEASE
<br />This Settlement Agreement and Release (the "Settlement Agreement ") is made and
<br />entered into this Sa day of NWch, 2016 by and among:
<br />0,0 Rt 1 0.s
<br />"Plaintiff' Hailley Hallstrom, by and through her guardian ad litem Tiffany Nunley
<br />"Defendant" City of Santa Ana
<br />RECITALS
<br />A. Plaintiff Hailley Hallstrom filed a complaint against City of Santa Ana and its
<br />police officers, in the United States District Court, Central District of California, entitled Tiffany
<br />Nunley, etc. v. City of Santa Ana, etal , which bears case number SACV 14 -0766 CAS (FFMx)
<br />(hereinafter "Action "). This Action arose out of the shooting, and subsequent incarceration and
<br />hospitalization, of Jason Hallstrom on March 15, 2013 and alleged civil rights violations and
<br />various state torts and negligent acts or omissions by the City and its police officers. In the
<br />Action, Plaintiff sought to recover monetary damages as a result of that certain occurrence on
<br />March 15, 2013, which allegedly resulted in physical injuries and personal injuries to Plaintiff
<br />and Decedent Jason Hallstrom.
<br />A- 2015 -305
<br />F.I.
<br />B. The parties desire to enter into this Settlement Agreement in order to provide for
<br />certain payments in full settlement and discharge of all claims which are, or might have been, the
<br />subject matter of the Complaint, upon the terms and conditions set forth below.
<br />AGREEMENT
<br />The parties agree as follows;
<br />1.0 RELEASE AND DISCHARGE
<br />IA In consideration of the payments set forth in Section 2, which has a current cost of
<br />one mullion six hundred thousand dollars and no cents ($1,600,000.00), including up -front cash
<br />and the promise of future periodic payments, Plaintiff hereby completely releases and forever
<br />discharges any named defendant in the Action, including but not limited to the City of Santa
<br />Ana, Officer John Rodriguez and Officer Peter Picone from any and all past, present or future
<br />claims, demands, obligations, actions, causes of action, wrongful death claims, rights, damages,
<br />costs, losses of services, expenses and compensation of any nature whatsoever, whether based on
<br />a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter
<br />accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the
<br />subject of the Action including, without limitation, any and all known or unknown claims for
<br />bodily and personal injuries to Plaintiff, or any future wrongful death claim of Plaintiff's
<br />representatives or heirs, which have resulted or may result from the alleged acts or omissions of
<br />the Defendant.
<br />IIPage
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