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INSURANCE NOT REQUIRED A-2016-381 <br />WORK MAY PROCEED <br />CLERK Of COUNCIL <br />DATE:,� 110 tol -2 <br />SETTLEMENT AGREEMENT <br />WHEREAS, KIMBERLY CERDA, (hereafter referred to as "Plaintiff') on or about <br />August 11, 2015, filed a civil lawsuit in the Orange County Superior Court, Case No. 30-2015- <br />00803814-CU-WT-CJC entitled: KIMBERLY CERDA v. CITY OF SANT ANA et al. <br />(Subject Lawsuit) against the City of Santa Ana (hereafter referred to as "Defendant'). <br />WHEREAS, the Plaintiff and Defendant recited herein above (hereafter, jointly, the <br />OParties"), without any admission of any fault, liability, or lack of merit as to any claim or <br />defense by any Party, are desirous of resolving their differences and settling all claims set <br />contained in said civil action, <br />IT IS THEREFORE AGREED BY EACH OF THE PARTIES TO SAID C17VIL <br />ACTION THAT: <br />Defendant agrees to make a total payment in the amount of EIGHTY-FIVE <br />THOUSAND DOLLARS.($85,000.00) ("Settlement Sum") to Plaintiff, as a complete <br />consideration for settlement of all of Plaintiff s claims against Defendant. In exchange for the <br />dismissal in Section 2 and the release of all claims as set forth in Section 2 below, the Parties <br />agree to settle this case for a total of Eighty -Five Thousand Dollars ($85,000.00). The total <br />settlement payment of Eighty -Five Thousand Dollars ($85,000.00) shall be made payable in <br />three (3) separate checks as follows: <br />a) The first check shall be made payable to Kimberly Cerda in the amount of Eight <br />Thousand Five Hundred Twelve Dollars and 24/100 ($8,512.24), as a "wage <br />payment," subject to all required deductions and withholdings. A W-2 statement <br />will be issued in the normal course of business; <br />