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GIOVANNY VELAZQUEZ AND JOSHUA COLEMAN
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GIOVANNY VELAZQUEZ AND JOSHUA COLEMAN
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Last modified
11/4/2020 9:55:12 AM
Creation date
11/4/2020 9:50:38 AM
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Contracts
Company Name
GIOVANNY VELAZQUEZ AND JOSHUA COLEMAN
Contract #
N-2020-197
Agency
City Attorney's Office
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INSURANCE NOT REOUIRED <br />WORK NIAY PROCEED <br />��- nrrr.. CLERK OF COUNCiI. <br />o� <br />N-2020-197 <br />SETTLEMENTRELEASE OF ALL <br />AND <br />CLAIMS <br />Q C(�o(o)CSAyaS)A is made <br />This Settlement Agreement and Release of All Claims (hereinafter "Agreement") <br />and entered into by and between GIOVANNY VELAZQLlEZ (hereinafter "Plaintiff), and <br />JOSHUA COLEMAN and CITY OF SANTA ANA (hereafter "Defendants")- <br />Ar'r� TH: <br />WHEREASPlaintiff anDefendants r Court of the t <br />California,CountyofOrang,Cetutce CenterDistricknown as GIOVANNY VELAZQUEZ <br />et at. Case No. 30-2020-01141075 (the <br />v JOSH[ IA CODY COLEMAN CITY OF SANTA ANA, <br />"Action"). <br />WHEREAS, Plaintiff and Defendants (collectively, the "Parties"), desire to settle fully <br />and finally all differences between them, including, but in no way limited to, those differences <br />described above. <br />NOW, THEREFORE, in consideration of the mutual covenants and paces es herein <br />wledged, <br />contained and other good and valuable consideration, receand between the Parties as followsof which is hereby : <br />and to avoid unnecessary litigation, it is hereby agreed by <br />FIR T: This Agreement and compliance with this Agreement shall not be construed as <br />an admission by Defendants of any liability whatsoever, or as an admission by Defendants of <br />any violation of the rights of Plaintiff or any person, violation any order, law, statute, duty, or <br />contract whatsoever against Plaintiff or any person. Defendd any <br />specifically disclaim any <br />laintiff or any <br />eged <br />liability to plaintiff or any other person <br />violation of foor anyy order, law, statute, duty, or colation of the gontrac hts ofton the part of <br />person, or for any g Nance with this <br />any employees or agents of Defendants. Likewise, this Agreement anliability, misconduct, or <br />Agreement shall not be construed as an admission by Plaintiff of any <br />wrongdoing whatsoever. <br />EC <br />(a) Each party will exchange a fully signed executed copy or original of this Agreement. <br />Defendants cannot process payment without a fully executed copy of the Agreement from <br />Plaintiff.of a Request for <br />(b) Following receipt of, or in exchange for, an executedDefendants will make <br />Dismissal form from Plaintiff dismissing this Action with prejudice, <br />available a check in the amount of Four Thousand Two Hundred Fifty Dollars ��amount <br />payable "GIOVANNY VELAZQUEZ AND KATNIK & KATNIIC, LAWYE in the <br />represents a full and complete settlement <br />ofor Plaintiffs <br />Dismsclasal follow' g receipt of samfor all damages e. Plaintiff and <br />The City of Santa Ana will file the Request <br />Defendants agree that this Agreement constitutes fall and complete s�emcompensation ifor <br />made against Defendants in this Action. Plaintiff will not seek any <br />any other claimed damages, costs, or attomey's fees in connection with the matters encompassed <br />in this Agreement. <br />Pagel of 4 <br />
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