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A-2025-023 <br />MAR 17 2025 <br />D.CPo«) <br />Ctpur0. Ro55in�m.r <br />SETTLEMENT AGREEMENT AND <br />SPECIFIC RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release of All Claims ("Agreement") dated March 7, 2025 is made <br />and entered into by and between SANTA ANA POLICE OFFICERS ASSOCIATION ("Plaintiff'), and <br />CITY OF SANTA ANA ("Defendant"). <br />WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State California, <br />County of Orange, Central Justice Center known as SANTA ANA POLICE OFFICERS ASSOCIATION <br />and DOE OFFICERS v. CITY OF SANTA ANA et al. Case No. 30-2021-01230134 (the "Action"). <br />WHEREAS, Plaintiff and Defendant (collectively, the "Parties"), desire to settle fully and finally <br />all differences between them, specifically those differences described above. <br />NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and <br />other good and valuable consideration, receipt of which is hereby acknowledged, and to avoid unnecessary <br />litigation, it is hereby agreed by and between the Parties as follows: <br />1. This Agreement and compliance with this Agreement shall not be construed as an admission <br />by Defendant of any liability whatsoever, or as an admission by Defendant of any violation of the rights of <br />Plaintiff or any person, violation of any order, law, statute, duty, or contract whatsoever against Plaintiff or <br />any person. Defendant specifically disclaims any liability to Plaintiff or any other person for any alleged <br />violation of the rights of Plaintiff or any person, or for any alleged violation of any order, law, statute, duty, <br />or contract on the part of any employees or agents of Defendant. Likewise, this Agreement and compliance <br />with this Agreement shall not be construed as an admission by Plaintiff of any liability, misconduct, or <br />wrongdoing whatsoever. <br />2. Each party will exchange a fully signed executed copy or original of this Agreement. <br />3. Within seven (7) days of receipt of the fully executed Agreement, Plaintiff will provide to <br />Defendant an executed copy of a Request for Dismissal form from Plaintiff dismissing all claims made by <br />Plaintiff in this Action with prejudice. Within thirty days (30) of the date the Agreement is fully executed, <br />Defendant will provide a check in the amount of Fifty Thousand Dollars ($50,000.00) made payable to <br />"SANTA ANA POLICE OFFICERS ASSOCIATION WIDOWS AND ORPHANS FUND" to Plamttff. <br />This amount represents a full and complete settlement of Plaintiffs claims for all damages alleged in the Action <br />and Plaintiff will agree to provide all necessary paperwork for issuance of the check as required by the City's <br />Finance Department including but not limited to a current W-9. The City of Santa Ana will file the Request for <br />Dismissal following receipt of the foregoing check by Plaintiffs counsel. <br />4. Plaintiff and Defendant agree that this Agreement constitutes full and complete settlement <br />of all claims made against Defendant in this Action. Plaintiff will not seek any further compensation for <br />any other claimed damages, costs, or attorney's fees in connection with the matters encompassed in this <br />Agreement. <br />5. Plaintiff acknowledges and agrees that Defendant has made no representations regarding the <br />tax consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that it and it alone <br />Page 1 of <br />