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2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />accommodations; and/or (e) the City's alleged inability to enforce any of the Anti - <br />Camping Ordinances and any law that the OCCW Releasing Parties claim <br />criminalizes a person's homeless status, against any person because of his or her <br />homeless status (collectively, the "OCCW Released Claims"). <br />6.2 The releases set forth in Section 6.1 are releases of all claims, <br />demands, causes of action, obligations, damages, and liabilities, of any nature <br />whatsoever, and are intended to encompass all known and unknown, foreseen and <br />unforeseen, claims that are possessed by the OCCW Releasing Parties and within <br />the scope of the OCCW Released Claims based solely and only on the events <br />giving rise to the OC Catholic Worker Action. To effectuate the intent of the <br />Parties, the OCCW Releasing Parties expressly agree to waive and relinquish all <br />rights and benefits they may have under California Civil Code Section 1542, which <br />reads as follows: <br />A general release does not extend to claims that the creditor or <br />releasing party does not know or suspect to exist in his or her favor at <br />the time of executing the release and that, if known by him or her, <br />would have materially affected his or her settlement with the debtor or <br />released party. <br />6.3 The OCCW Releasing Parties warrant that they have made no <br />assignment, and will make no assignment, of any claim, chose in action, right of <br />action, or any right, of any kind whatsoever, within the scope of the OCCW <br />Released Claims, and that no other person or entity of any kind had or has any <br />interest in any of the demands, obligations, actions, causes of action, debts, <br />liabilities, rights, contracts, damages, attorney's fees, costs, expenses, losses, or <br />claims within the scope of the OCCW Released Claims. <br />7. Dismissal of the OC Catholic Worker Action <br />Upon entry of the Court's Order re Continuing Jurisdiction and Settlement, <br />the OCCW Plaintiffs, as to the City, will take all necessary actions and file all <br />13 <br />25H-16 <br />