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INSURANCE NOT REQUIRED <br />WORK MAY PROCEED <br />Ci_riv CF COUNCIL <br />N-2019-143 <br />AUG 14 2019 <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 CITY OF SANTA ANA ("City"), on the one side, and Property Owners, ALEX <br />TAYEBI and KRISTY GOODMAN (herein collectively referenced as "Property Owners"), <br />on the other side. City and Property Owners are sometimes individually referred to herein as a <br />t "Party" and collectively referred to herein as the "Parties." <br />This Agreement is made with reference to the following facts: <br />RECITALS <br />A. WHEREAS, the City of Santa Ana is a city organized under the laws of the State <br />of California, with a duty and interest in protecting the public health, safety, and welfare within <br />the city; <br />B. WHEREAS, Property Owners are the current owners of property located at 1906 <br />S. Main Street, Santa Ana, California (the "Property"); <br />C. WHEREAS, the City has taken extensive action against the Property due to <br />numerous longstanding violations of the Santa Ana Municipal Code (SAMC) and other adopted <br />codes. Specifically, the Property has been extensively modified without building permits, <br />inspections, or approvals, and has been used as an illegal marijuana dispensary facility. Based on <br />these violations, the City has declared the property to be a public nuisance. Pursuant to the Santa <br />Ana Municipal Code and authorized by a court -issued warrant, the City has installed security <br />doors and screens throughout the property and retained security guards to prevent further access <br />in order to temporarily abate the public nuisance. In addition, the City has issued a Notice and <br />Order against the property, pursuant to the SAMC and other adopted codes <br />D. WHEREAS, 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 1 of 7 <br />