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APR -5 -2016 02:22P FROM:NUNLEY BUSINESS 7148843846 70:15626241176 P.2
<br />1.2 This release and discharge shall apply to the past, present and future officers,
<br />directors, stockholders, attorneys, agents, servants, representatives, employees, subsidiaries,
<br />affiliates, partners, predecessors and successors in interest, and assigns and all other persons,
<br />firms or corporations with whom any of the former have been, are now, or may hereafter be
<br />affiliated of the City of Santa Ana, including but not limited to Officer John Rodriguez and
<br />Officer Peter Picone.
<br />1.3 This release, on the part of the Plaintiff, shall be a fully binding and complete
<br />settlement among the Plaintiff and the Defendant, and their heirs, assigns and successors and
<br />employees, including, but not limited to Officer John Rodriguez and Officer Peter Picone.
<br />1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth
<br />above is a general release. Plaintiff expressly waives and assumes the risk of any and all claims
<br />for damages which exist as of this date, but of which the Plaintiff does not know or suspect to
<br />exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if
<br />known, would materially affect Plaintiff's decision to enter into this Settlement Agreement. The
<br />Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a
<br />complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes the
<br />risk that the facts or law may be other than Plaintiff believes. It is understood and agreed to by
<br />the parties that this settlement is a compromise of a doubtful and disputed claim, and the
<br />payments are not to be construed as an admission of liability on the part of the Defendant, by
<br />whom liability is expressly denied.
<br />2.0 PAYMENTS
<br />In consideration of the release set forth above, the Defendant agrees to pay the payments
<br />outlined in Sections 21 and 2.2 below:
<br />2.1 Payments due at the time of settlement as follows:
<br />$778,505.00 shall be in the form of a check made payable to
<br />''() ut' p jt /_.,.. Jt �'iNlf�� /l�x�'%i'✓�i F4cc' -.+'i
<br />2.2 The Periodic Payments which constitutes damages (other than punitive damages)
<br />received on account of Plaintiff's alleged personal physical injuries or sickness within the
<br />meaning of section 104(a)(2) of the Internal Revenue Code of 1986, will be paid as follows:
<br />Payee: Tiffany Nunley, as the mother of and guardian ad litem for Hailley Hallstrom
<br />$7,500.00 Payable semi- annually for four years, all guaranteed, beginning August 1,
<br />2017, with the final guaranteed payment made on February 1, 2021.
<br />Payee: Hailley Hallstrom
<br />$50,000.00 Guaranteed lump sum, payable on April 22,2020;
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