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RF.L,I SE� TI'S LJLL SE!, Frf EM]�IdIpL1 �lNI)p � . C'(1(�p�7�C)1o��g,
<br />1. I, Raven Starr Shine, the undersigned, for and in consideration of
<br />the sum of one million six luaadrecl thousand dollars (,$1,600,000.04), for
<br />rrryself, my heirs, executors, administrators, and assigns do hereby remise,
<br />release and forever discharge the City of Santa Ana, Chief Carlos Rojas,
<br />Corporal Anthony Bertagna, Detective Leo Rodriguez, Officer John Rodriguez
<br />and Officer Peter Pieone, their principals, employees, ofCcers, agents, claims
<br />administrators„ attorneys and insurers [hereinafter referred to as "Releasees "],
<br />from any and all claims and carises of ac Lion lay reason of any injury, damage
<br />or civil rights violations, itwhuling any and ail attorney's fees and costs, which
<br />I have sustained, or inay have sustained, as a. result of the events surrounding
<br />the detention, shooting and subsequent hospitalization of Jason Hal'lstrom oil
<br />March 15, 2013, as more fully described in the Second Amended Complaint
<br />filed by me in the United. States District Court - -- Central District of California
<br />in the matter entitled R.S, ct al. v. (7ity raf,5'antca Ana, et al„ and which bears
<br />case number SACV14 -0589 CAS ('F.FM.,t).
<br />21 it is expressly understood and agree([ that This release governs all
<br />claims and. causes of action, including any alleged civil rights violations, and
<br />state torts, and all injuriea and damages that arise out of the allegations in the
<br />action entitled R.,S„ et al. v, City of Sanla Ana, et at, and which bears case
<br />number SACV 1.4-0589 CAS (Fr-Mx) pending in the United States District
<br />Court, Central ]district of California.
<br />3, It is further understood and agreed that this settienaent is the
<br />compromise of a doubtful and disputed claim, and that the payment herein
<br />provided for is not to be construed as an admission of liability, which is
<br />expressly denied.
<br />4, As a further consideration and inducement for this compromised
<br />settlement, tire following provisions of California Civil Code section 1542 are
<br />hereby expressly waived:
<br />A general ,release does not extend to claims which the
<br />creditor does not lwow or suspect to exist in her favor at
<br />the time of "executing of the release, which if known by
<br />incur must have materially affected her settleaaaent with
<br />the debtor.
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