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TERMS OF SETTLEMENT AGREEMENT
<br />The terms and conditions of the Settlement are provided herein.
<br />2. Fines. Fees. and Abatement Costs. In consideration for the final settlement of this
<br />matter, and in accordance with the terms of this Agreement, Property Owners stipulate and agree
<br />to pay the City a total of Twenty -Nine Thousand, Two Hundred and Ninety -Four U.S. Dollars
<br />and Ten Cents ($29,294.10) in fines, fees, and abatement costs (`Settlement Payment"). The
<br />Settlement Payment shall made payable to the City within thirty (30) days of the execution of this
<br />Settlement Agreement. The Settlement Payment shall be made to "City of Santa Ana" as follows:
<br />City of Santa Ana, Santa Ana City Attorney's Office, 20 Civic Center Plaza, M29, P.O. Box
<br />1988, Santa Ana, California 92702.
<br />3. Release. Except for the obligations and covenants provided herein, the Property
<br />Owners, on behalf of themselves and past, present, and future predecessors, successors, affiliates,
<br />heirs, assigns, officers, officials, directors, shareholders, members, managers, agents, employees,
<br />servants, trustees, fiduciaries, parent and subsidiary organizations, partners, attorneys, insurers,
<br />representatives, accountants, and all persons acting by, through, under, or in concert with them,
<br />or any of them, and each of them (collectively referred to herein as the "Releasing Parties"),
<br />hereby release, relinquish, acquit, remise, and discharge City, and its past, present, and future
<br />predecessors, successors, affiliates, heirs, assigns, officers, officials, directors, managers, agents,
<br />employees, servants, trustees, fiduciaries, subsidiary organizations, partners, attorneys, insurers,
<br />representatives, accountants, and all persons acting by, through, under, or in concert with them,
<br />or any of them, and each of them (collectively referred to herein as the "Released Parties"), from
<br />any and all past, or present rights, claims, demands, obligations, losses, debts, liabilities, offsets,
<br />promises, acts, omissions, agreements, costs and expenses, damages, injuries, suits, allegations,
<br />appeals, actions and causes of action for damages, equitable relief, and compensation of every
<br />kind and nature whatsoever, whether known or unknown, suspected or unsuspected, contingent
<br />or fixed, whether past or present whether based in contract, tort, statute, or other legal or
<br />equitable theory of recovery, which, as of the date of this Agreement, the Releasing Parties have
<br />or had acquired by the Releasing Parties against any of the Released Parties, arising out of,
<br />concerning, pertaining to, or in any way connected to the Property Owners' ownership and use of
<br />property in Santa Ana as a nuisance within the meaning of the Santa Ana Municipal Code.
<br />These released claims are collectively referenced herein as the "Claims."
<br />4. California Civil Code Section 1542 Waiver. With respect to the released Claims
<br />set forth herein, the Property Owners acknowledge that they has been advised by legal counsel
<br />and are familiar with the provisions of California Civil Code Section 1542, which provides as
<br />follows:
<br />"A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS
<br />WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT
<br />TO EXIST IN HIS OR ITS FAVOR AT THE TIME OF
<br />EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR
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