Plaintiff waives all rights that he or she has or may have under Section 6149.5 of the
<br />California Business and Professions Code, which requires a copy of the cover letter accompanying
<br />the Settlement Funds paid as described in this Agreement be sent to Plaintiff herein. , Plaintiff
<br />authorizes and directs that the Settlement Funds to be paid as described in this Agreement will be
<br />sent or delivered to Plaintiff's attorney within ten business days after Plaintiff gives notice to the
<br />Court that there has been a full and complete settlement reached by all parties in the case.
<br />2. FULL SETTLEMENT.
<br />By his or her signature on this Agreement, Gilbert Castrejon, on behalf of him/herself and
<br />his or her Related Persons, as defined in Paragraph 3.1 below, agrees to accept such Settlement
<br />Funds without any further demand to Santa Ana and Orange or their Related Persons, as defined
<br />in Paragraph 3.2 and 3.3 below, respectively, for any financial or other consideration beyond that
<br />set forth in this Agreement. By his or her signature on this Agreement, Gilbert Castrejon agrees
<br />that the City of Santa Ana and the City of Orange and their Related Persons will have fulfilled
<br />their obligations under this Agreement once the agreed upon terms as provided in Paragraph 1
<br />above have been performed.
<br />3. RELEASES.
<br />3.1 As used herein, "Related Persons" when used with respect to "Gilbert Castrejon"
<br />shall mean all partners, employees, agents, servants, trustees, attorneys, brokers, third -party
<br />administrators, sureties, predecessors, lien holders, judgment creditors, successors, assigns, and all
<br />other affiliated, related and involved persons and entities past, present and future.
<br />3.2 As used herein, "Related Persons" when used with respect to the "City of Santa
<br />Ana" shall mean all officers, board members, council members, .directors, partners, employees,
<br />agents, servants, trustees, attorneys, parent companies, subsidiaries, subcontractors, insurers,
<br />reinsurers, brokers, third party administrators, sureties, predecessors, lien holders, judgment
<br />creditors, successors, assigns, and all other affiliated, related and involved persons and entities
<br />past, present and future.
<br />3.3 As used herein, "Related Persons" when used with respect to the "City of Orange"
<br />shall mean all officers, board members, council members, directors, partners, employees, agents,
<br />servants, trustees, attorneys, parent companies, subsidiaries, subcontractors, insurers, reinsurers,
<br />brokers, third party administrators, sureties, predecessors, lien holders, judgment creditors,
<br />successors, assigns, and all other affiliated, related and involved persons and entities past, present
<br />and future.
<br />3.4 As used herein, "Claims" shall mean any and all past, present and future claims,
<br />demands, obligations, liabilities, costs, expenses, attorney's fees, damages, suits, actions, causes
<br />of actions, judgments, liens, applications, and disputes of any nature whatsoever whether actually
<br />asserted or which could have been asserted, whether known or unknown, suspected or
<br />unsuspected, actual or potential, absolute or contingent, pending or anticipated, in law and/or
<br />equity arising from or related to the Incident and the Incident Location.
<br />-2-
<br />
|