Laserfiche WebLink
A-2021-142 <br />N <br />O <br />N 11;;'- Aio 7QUIRED <br />CO W(:i IF'OCEF ) <br />oco SETTLEMENT AGREEMENT <br />AND RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release of All CIaims ("Agreement") is made and entered <br />into by and between GONZALO CARLOS AND JENNIFER SALGADO (collectively, <br />"Plaintiffs"), and CITY OF SANTA ANA and MARIBEL CASILLAS (collectively <br />"Defendants"). <br />O:C'� ��•1 ���wylve. <br />WHEREAS, Plaintiffs filed an action against Defendants in the Superior Court of the <br />State California, County of Orange, Central Justice Center District known as GONZALO <br />CARLOS & JENNIFER SALGADO v. CITY OF SANTA ANA, MARIBEL CASILLAS, Case <br />g W4rZ / WITNESSETH: <br />No. 30-2020-01145192-CU-PA-CJC (the "Action"), <br />WHEREAS, Plaintiffs 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 Plaintiffs or anyperson, violation of any order, law, statute, duty, or contract <br />whatsoever against Plaintiffs or any person. Defendants specifically disclaim any liability to <br />Plaintiffs or any other person for any alleged violation of the rights of Plaintiffs or any person, or <br />for any alleged violation of any order, law, statute, duty, or contract on the part of any employees <br />or agents of Defendants. Likewise, this Agreement and compliance with this Agreement shall not <br />be construed as an admission by Plaintiffs 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 Plaintiffs dismissing this Action with prejudice, Defendants will make <br />available two checks that total Sixty Four Thousand Two Hundred Fifty Dollars ($64,250.00). One <br />check will be made payable to "GONZALO CARLOS AND AVREK LAW FIRM, " in the amount <br />of $15,000. The second check will be made payable to"JENNIFER SALGADO AND AVREK <br />LAW FIRM, " in the amount of $49,250 These amounts represent a fall and complete settlement of <br />Plaintiffs' claims for all damages alleged in the Action. The City of Santa Ana will file the Request <br />for Dismissal following receipt of the foregoing checks by Plaintiffs' counsel. <br />4. Plaintiffs and Defendants agree that this Agreement constitutes full and complete <br />settlement of all claims made against Defendants in this Action. Plaintiffs will not seek any <br />Page t of 4 <br />