My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
RANGEL, MARBELLA
Clerk
>
Contracts / Agreements
>
R
>
RANGEL, MARBELLA
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
7/16/2021 11:42:45 AM
Creation date
7/16/2021 11:42:02 AM
Metadata
Fields
Template:
Contracts
Company Name
RANGEL, MARBELLA
Contract #
A-2021-125
Agency
City Attorney's Office
Council Approval Date
7/6/2021
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
4
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
"N'6iRAaI - 'CQUIRED <br />W( PRQCEEp <br />JUL 15 2021 OUNr; ,L <br />SETTLEMENT AGREEMENT <br />AND Q : ( (- j A �16 rvt j (K�1 b • eU ese^) (4µ) g LEASE OF ALL CLAIMS <br />A-2021-125 <br />This Settlement Agreement and Release of All Claims ("Agreement") is made and entered <br />into by and between MARBELLA RANGEL ("Plaintiff'), and CITY OF SANTA ANA and <br />CHRISTOPHER DONAHUE (collectively, "Defendants"). <br />WITNESSETH: <br />WHEREAS, Plaintiff filed an action against Defendants in the Superior Court of the State <br />California, County of Orange, Central Justice Center known as MARBELLA RANGEL v. CITY OF <br />SANTAANA, et al., Case No. 30-2019-01110037-CU-PA-CJC (the "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 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 />1. This Agreement and compliance with this Agreement shall not be construed as an <br />admission by Defendants of any liability whatsoever, or as an admission by Defendants 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. Defendants specifically disclaim 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 Defendants. 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 />2. Each party will exchange a fully signed executed copy or original of this <br />Agreement. Defendants cannot proceed with processing payment without a fully executed copy of <br />the Agreement from Plaintiff. <br />3. Following receipt of, or in exchange for, an executed copy of a Request for <br />Dismissal form from Plaintiff dismissing this Action with prejudice, Defendants will make <br />available a check in the amount of One Hundred and Twenty -Five Thousand Dollars <br />($125,000.00) made payable "MARBELLA RANGELAND LAW OFFICES OF GENE J. <br />GOLDSMAN." This amount represents a full and complete settlement of Plaintiffs claims for all <br />damages alleged in the Action. The City of Santa Ana will file the Request for Dismissal following <br />receipt of the foregoing check by Plaintiffs counsel. <br />4. Plaintiff and Defendants agree that this Agreement constitutes full and complete <br />settlement of all claims made against Defendants in this Action. Plaintiff will not seek any <br />further compensation for any other claimed damages, costs, or attorney's fees in connection with <br />the matters encompassed in this Agreement. <br />Plaintiff acknowledges and agrees that Defendants have made no representations <br />Page] of 4 <br />
The URL can be used to link to this page
Your browser does not support the video tag.