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A-2019-055 WOW ho 1Y k'htlCl f [i APRs j c 2019 SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS ` �Aa V.�� This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made and entered into by and between NORMA DOMINGUEZ (hereinafter "Plaintiff'), and CITY OF SANTA ANA (hereafter "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 NORMA DOMINGUEZ v. CITY OF SANTA ANA Case No. 30-2017-00935598-CU-PO-CJC (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. 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: FIRST: This Agreement and compliance with this Agreement shall not be construed as an admission by Defendant of any lability whatsoever, or as an admission by Defendant of any violation of the rights of Plaintiffor anyperson, 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. SECOND: (a) 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. (b) 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 and Fifty Thousand Dollars ($250,000) made payable to "NORMA DOMINGUEZ AND SHANK N STEEL LAW FIRM." This amotimt represents full and complete settlement of Plaintiffs claims for all damages alleged in the Action. The City of Santa Ana can file the Request for Dismissal. Plaintiff and Defendant agree 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. Page 1 of