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21. No New Lawsuit.
<br />Effective only upon the adoption of the Proposed Ordinance referenced in
<br />Paragraph 6, and the payment of the attorneys' fees, cost, and expenses detailed in
<br />Paragraph 14, Plaintiff agrees that she will not file another lawsuit asserting a claim
<br />under the CVRA, the federal Voting Rights Act, the City's at -large electoral system, or
<br />California Code of Civil Procedure § 1021.5 based on the facts alleged (or facts that
<br />could have been alleged) in the Complaint in the CVRA Lawsuit. Nothing in this
<br />paragraph shall be understood to limit Plaintiffs efforts to organize community
<br />members to support passage of the ballot measure to convert the City's election
<br />system to by -district elections. Furthermore, nothing in this paragraph shall be
<br />understood or construed to limit Plaintiffs right to pursue litigation to enforce the
<br />terms of this Agreement or the Stipulated judgment referenced in Paragraph 8
<br />herein.
<br />22. Release of Claims.
<br />Effective only upon the adoption of the Proposed Ordinance referenced in
<br />Paragraph 6, and the payment of the attorneys' fees, cost, and expenses detailed in
<br />Paragraph 14, the Parties, for themselves and their past, present or future heirs,
<br />beneficiaries, executors, administrators, officers, employees, directors, agents,
<br />partners, successors and assigns, including past, present or future City Council
<br />members and Mayors ("Releasors"), do hereby fully release, acquit, waive and
<br />forever discharge one another, including their heirs, beneficiaries, executors,
<br />administrators, officers, employees, directors, agents, partners, successors and
<br />assigns, and their past, present or future City Councilmembers and Mayors,
<br />("Releasees"), from any and all claims, actions, causes of action, factual allegations,
<br />demands (including without limitation demands for equitable and injunctive relief,
<br />debts, damages, costs, expenses including expert fees, losses, or attorney's fees) for
<br />any and all claimed violations of the federal Voting Rights Act, the CVRA, the City's
<br />at -large electoral system, or California Code of Civil Procedure § 1021.5 ("Claims")
<br />arising out of, based on, or related to the facts alleged (or facts that could have been
<br />alleged) in the Complaint in the CVRA Lawsuit, which Claims the Releasors have or
<br />may have against the Releasees, except for rights to enforce this Agreement, or as
<br />otherwise provided herein. In this Paragraph, the conjunctive includes the
<br />disjunctive.
<br />23. Express Waiver of All Claims Under California Civil Code Section 1542.
<br />It is further understood and agreed that this Agreement extends to all of the
<br />above-described Claims and potential Claims as described in Paragraph 22, arising
<br />out of, based on, or related to the facts alleged (or facts that could have been
<br />alleged) in the Complaint in the CVRA Lawsuit, and that all rights under California
<br />Civil Code §1542 are hereby expressly waived by the Parties for themselves and the
<br />other Releasors with respect to all such Claims. Section 1542 provides as follows:
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