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IN �;iA NCE NOT REQUIRED <br />ORKMAY PROCEED <br />nnr`r. CLERK OF COUNCIL <br />9, Awl <br />Ck(7 t,�µ.�av �tlta �i l�ale�ror dl <br />SETTLEMENT AGREEMENT <br />AND RELEASE OF ALL CLAIMS <br />A-2020-046-01 <br />This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made <br />and entered into by and between ANA MANJARREZ (hereinafter "Plaintiff'), and CITY OF <br />SANTA ANA (hereafter "Defendant"). <br />WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State <br />California, County of Orange, Central Justice Center District known as ANA MANJARREZ v. CITY <br />OF SANTAANA, et al., Case No. 30-2019-01060879-CU-PO-CJC (the "Action"). <br />WHEREAS, Plaintiff, ANA MANJARREZ, and Defendant (collectively, the <br />"Parties"), desire to settle fully and finally all differences between them, including, but in no way <br />limited to, those differences described above. <br />NOW, THEREFORE, in consideration of the mutual covenants and promises herein <br />contained and other good and valuable consideration, receipt of which is hereby acknowledged, and <br />to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows: <br />FIRST: This Agreement and compliance with this Agreement shall not be construed as an <br />admission by Defendant of any liability whatsoever, or as an admission by Defendant of any <br />violation of the rights of Plaintiff or any person, violation of any order, law, statute, duty, or contract <br />whatsoever against Plaintiff or any person. Defendant specifically disclaims any liability to <br />Plaintiff or any other person for any alleged violation of the rights of Plaintiff or any person, or for <br />any alleged violation of any order, law, statute, duty, or contract on the part of any employees or <br />agents of Defendant. Likewise, this Agreement and compliance with this Agreement shall not be <br />construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. <br />SECOND: (a) Each party will exchange a fully signed executed copy or original of this <br />Agreement. Defendant cannot proceed with processing payment without a fully executed copy of <br />the Agreement from Plaintiff. <br />(b) Following receipt of, or in exchange for, an executed copy of a Request <br />for Dismissal form from Plaintiff dismissing this Action with prejudice, Defendant, CITY OF <br />SANTA ANA, will make available a check in the amount of Seven -Five Thousand Dollars <br />($75,000.00) made payable "ANA MANJARREZ AND DOWNTOWN LA LAW GROUP". <br />These amount represents a full and complete settlement of Plaintiffs claims for all damages alleged in <br />the Action. The City of Santa Ana will file the Request for Dismissal following receipt of same. Plaintiff <br />and Defendant agree that this Agreement constitutes full and complete settlement of all claims <br />made against Defendant in this Action. Plaintiff will not seek any further compensation for any <br />other claimed damages, costs, or attorneys fees in connection with the matters encompassed in <br />this Agreement. <br />(c) Plaintiff acknowledges and agrees that Defendant has made no <br />representations regarding the tax consequences of any amounts received pursuant to this <br />Agreement. Plaintiff agrees that she and she alone is liable for all taxes, if any, which are owed <br />Page 1 of 4 <br />