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a. The Parties to this Agreement agree not to disclose or cause to be <br />disclosed, either directly or indirectly, to any person or entity, the monetary or other <br />material terms of this Agreement. <br />b. As necessary, however, the Parties may disclose the monetary terms of this <br />Settlement Agreement to: (i) the court as necessary to obtain approval of a dismissal of <br />the Lawsuit or to enforce the Judgment for Possession, so long as the material terms of <br />the Agreement are not disclosed in any public document, record, or file; (ii) their legal <br />counsel, spouses and/or accountants to the extent necessary for the provision of legal <br />and/or tax advice; (lii) any state or federal tax authorities, and/or (iv) any court with <br />jurisdiction over a party, which court orders the disclosure of this information. However_, <br />as to any of these permissible disclosures identified herein, the party or entity to whom <br />the information is disclosed shall be advised of the confidential nature of this settlement <br />and the parry shall request that they abide by this confidentiality term. <br />Agreed as to revised C. Except as provided in subpart (b), if asked by any person or entity about <br />version of para. 12.c.: this litigation, the Parties may respond and disclose only that the Lawsuit was settled on a <br />Plaintiff confidential basis and that they cannot comment on this settlement. Subparts a., b., c., do not <br />apply to public record requests received by any of the public entities involved in this litigation. <br />USEty D of Murrieta d. The Parties represent, covenant, warrant and agree that, prior to the <br />execution of this Settlement Agreement, they have not disclosed any material terms of <br />City of Santa this Agreement to any other person or entity, except as allowed by Paragraph 4. <br />Ana <br />e. The Parties represent, acknowledge, agree and covenant that, but for this <br />Confidentiality provision, the other parties to this Agreement would not have entered into <br />a settlement and that this confidentiality provision was highly material to the settlement. <br />The Parties, and each of them, further represent, acknowledge, warrant and agree that, if <br />there is any violation of this ton fidentiality provision by any party, it shall constitute an <br />incurable breach of this agreement and shall entitle the other party to sue for damages, <br />including but not limited to return of all settlement monies received by the breaching <br />party(ics). <br />13, This Agreement is the result of negotiation between the parties hereto and is the <br />fully integrated and final expression of the settlement described herein. This Agreement may not <br />be altered, changed, or amended without a written document signed by all of the following <br />entities: MORAIN and authorized representatives of CITY OF MURRIETA, MURRIETA <br />VALLEY UNIFIED SCHOOL DISTRICT and CITY OF SANTA ANA. <br />14_ By executing this Release, each party acknowledges that he/she/it/they has/have <br />read and understands each and every provision of this Release, and by placing his/her/its/their <br />signature at the end of this Agreement represents that he/she/it/they has/have voluntarily assumed <br />,A 5of8 <br />Plaintiff Initial <br />General Release and Settlement Agreement <br />COLBYMORA/NY. C/TYOFMURRIETA <br />Pettit Kohn File No. 323-7137 <br />Client File No.: 1.099-1023557 <br />