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INSURANCE NOT REQUIRED <br />WORK MAY PROCEED <br />CLERK OF COUNCIL <br />F"3 0 i 2019 <br />®`.CAoco) <br />/1J'kNC. �.iFr=.h+�CS <br />N-2019-425 <br />SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release (hereinafter "Agreement') is made and entered into <br />by and between Plaintiff CITY OP SANTA ANA (- City), on the one side, and Property Owners. <br />JAMES S. HONG, KOOK It. HONG and ENVISION PROPERTIES. LLC (herein <br />referenced as "Settling Property Owners—), on the other side. City and Settling Property Owners <br />are sometimes individually referred to herein as a `Party' and collectively referred to herein as the <br />"Parties." <br />This Agreement is made with reference to the following facts: <br />RECITALS <br />A. WIIEREAS, the City of Santa Ana is a city organized under the laws of the State <br />of Califomia, with a duty and interest in protecting the public health, safety. and welfare within <br />the cin•• <br />B. W7IEREAS, the Scaling Property Owners arc the current owners of property <br />located at 902-414 N. Harbor, Santa Ana, California 92704 (the "Property"). <br />C. WHEREAS, on August 30, 2018, City sent Settling Property Owners a Cease and <br />Desist Letter regarding the illegal use of the Property and the public nuisances on the property <br />pursuant to the Red Light Abatement Act (Penal Code §11225 et seq.). City advised Settling <br />PropeM, Owners that the Property was being used for the purposes of prostitution and as such, is <br />a nuisance per se. <br />D. N7IEREAS, the Parties desire to avoid the expense, inconvenience, and <br />uncertainties of further litigation and, therefore, the Parties have agreed, with no admission of <br />liability by any Party, to enter into a complete and final settlement of all disputes, Claims (as <br />defined in paragraph 4 below), and differences between them; and <br />NOW THEREFORE, IN CONSIDERATION of the above recitals, the covenants. <br />conditions, and agreements made herein by the Parties. and other good and valuable <br />consideration, the receipt and sufficiency of which are hereby acknowledged. the Parties agree as <br />follows: <br />Page I of 9 <br />