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IitiSCItAil,JC�L PJDT REWIRED A-2025-191 �gORK NlAY PROCEED CIiY CLERK DATE: DEC 0 3 2025 o . oRo (ai) Sandra Flora/ SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS A'Oean lon(4Gia 07) This Settlement Agreement and Release of All Claims ("Agreement") is made and entered into by and between PAUL PASSERO ("Plaintiff'), and the CITY OF SANTA ANA ("Defendant"). WITNESSETH: WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State California, County of Orange, Central Justice Center District known as PAUL PASSERO v. CITY OF SANTA ANA, Case No. 30-2023-01352146-CU-PO-WJC (the "Action"). WHEREAS, Plaintiff and Defendant (collectively, the "Parties"), desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described above. This Agreement hereby documents a global settlement between the parties of all issues arising from the Action. NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and other good and valuable consideration, receipt of which is hereby acknowledged, and to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows: 1. This Agreement and compliance with this Agreement shall not be construed as an admission by Defendant of any liability whatsoever, or as an admission by Defendant of any violation of the rights of Plaintiff or any person, violation of any order, law, statute, duty, or contract whatsoever against Plaintiff or any person. Defendant specifically disclaims any liability to Plaintiff or any other person for any alleged violation of the rights of Plaintiff or any person, or for any alleged violation of any order, law, statute, duty, or contract on the part of any employees or agents of Defendant. Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. 2. Each party will exchange a fully signed executed copy, or original, of this Agreement. Defendant cannot proceed with processing payment without a fully executed copy of the Agreement from Plaintiff. 3. Following receipt of, or in exchange for, an executed copy of a Request for Dismissal form from Plaintiff dismissing this Action with prejudice, Defendant will make available a check in the amount of Two Hundred Forty Nine Thousand Dollars ($249,000) made payable to "PAUL PASSERO AND JSM INJURY FIRM APC". This amount represents a full and complete settlement of Plaintiffs claims for all damages alleged in the Action. Defendant will file the Request for Dismissal following Plaintiffs receipt of the settlement check. Plaintiff agrees that this Agreement constitutes full and complete settlement of all claims made against Defendant in this Action. Plaintiff will not seek any further compensation for any other claimed damages, costs, or attorney's fees in connection with the matters encompassed in this Agreement. 4. Plaintiff acknowledges and agrees that Defendant has made no representations regarding the tax consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that he and he alone is liable for all taxes, if any, which are owed by him on any amount received hereunder including interest and penalties. Plaintiff will hold Defendant harmless from any and all claims made by federal, state, or local taxing authorities against Plaintiff on amounts owed by them. Page t of 4