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RELEASE JAI FULL SET TLE1V ENT AND CO14f1'RC6'1V ISE
<br />L 1, Phyllis Hallstrom, the undersigned, for and in consideration of
<br />the sum of five hundred thousand dollars ($500,000.00), for myself, my heirs,
<br />executors, administrators, and assigns do hereby remise, release and forever
<br />discharge the City of Santa Ana, Chief Carlos Rojas, Corporal Anthony
<br />Bertagna, Detective Leo Rodriguez, Officer John Rodriguez and Officer Peter
<br />Picone, their principals, employees, officers, agents, claims administrators,
<br />attorneys and insurers [hereinafter referred to as "Releasees "], from any and all
<br />claims and causes of action by reason of any injury, damage or civil rights
<br />violations, including any and all attorney's fees and costs, which 1 have
<br />sustained, or may have sustained, as a result of the events surrounding the
<br />detention, shooting and subsequent hospitalization of my son Jason Hallstrom
<br />on March 15, 2013, as more fully described in the Second Amended Complaint
<br />filed by me in the Unted States District Court -- Central District of California
<br />in the matter entitled. R.S., et al. v. City of Santa Aria, et al,, and which bears
<br />case number SACV14 -0589 CAS (FFMx),
<br />2. It is expressly Gulderstood and agreed that this release governs all
<br />clairns and causes of action, including any alleged civil rights violations, and
<br />state torts, and all injuries and damages that arise out of the allegations in the
<br />action entitled R.S., et cit. Y. City of Santa Ana, et ar /., and, which bears case
<br />number SACV14 -05 89 CAS (FFMx) pending in the United States District
<br />Court, Central District of California,
<br />3, It is further understood and agreed that this settlement 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, the 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 know or suspect to exist in her favor at
<br />the time of executing of the release, which if known by
<br />him must have materially affected her settlement with
<br />the debtor,
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