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payments owed to Medicare. Check to be mailed to Gibson & Hughes Attorneys at Law, who will be responsible for payment to Medicare. (e) Parties agree that this Agreement and the payments specified in subsections c-d above, constitute full and complete settlement and compromise of all claims made against the Defendant in the Action. Plaintiff specifically agrees that by accepting the foregoing payments and executing this Agreement, Plaintiff is waiving any and all actual or potential rights to any other claimed damages, costs, or attorney's fees in connection with the Action. (f) 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 she and she alone is liable for all taxes, if any, which are owed by her 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 or lien holders against Plaintiff on amounts owed by her. THIRD: Plaintiff represents that, with the exception of this Action and the government tort claim associated therewith and submitted to the City of Santa Ana, she has not filed any complaints, claims, or actions against Defendant including any of its officers, agents, directors, supervisors, employees, or representatives of Defendant with any state, federal, or local agency or court and that she will not do so at any time hereafter as it relates to this Action and that if any agency or court assumes jurisdiction of any complaint, claim, or action against Defendant on Plaintiff s behalf, Plaintiff will direct that agency or court to withdraw and dismiss the matter with prejudice. FOURTH: The Parties hereto hereby agree that all rights under Section 1542 of the Civil Code of the State of California are hereby waived. Civil Code Section 1542 provides as follows: "A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor." FIFTH: Notwithstanding the provisions of Civil Code section 1542, each party hereby irrevocably and unconditionally releases and forever discharges each other party and each and all of its officers, agents, directors, supervisors, employees, representatives, and its successors and assigns and all persons acting by, through, under, or in concert with each other party from any and all charges, complaints, claims, and liabilities of any kind or nature whatsoever, known or unknown, suspected or unsuspected (hereinafter referred to as "claim" or "claims") which each releasing party at any time heretofore had or claimed to have or which each releasing party at any time hereafter may have or claim to have, incidental to the incident(s) which form the basis of the Action. SIXTH: Each person signing below represents that he/she has reviewed all aspects of this Agreement, that the Agreement has been carefully read and fully explained to them and that they understand every provision of this Agreement, that they understand that in agreeing to this document they are releasing each party hereby from any and all claims they may have against each party released, that they voluntarily agree to all the terms set forth in this Agreement, that they knowingly and willingly intend to be legally bound by the same, that they were given the Page 2 of 4