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3 <br />tioti� <br />Sc�Q 1 INSURANCE NOT REQUIRED <br />WORK MAY PROCEED <br />CLERK OF COLUX <br />MDC000�ehronfoyo) <br />SETTLEMENT AGREEMENT AND <br />RELEASE OF ALL CLAIMS <br />N-2021-176 <br />This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made <br />and entered into by and between CITY OF SANTA ANA, a charter City and municipal <br />corporation (the "City"), and THE PEOPLE OF THE STATE OF CALIFORNIA, (hereinafter <br />"Plaintiffs"), and CARL P. & MARION B. STEVENS TRUST, under declaration of trust dated <br />September 15, 1989; RON STEVENS, as co -trustee; and JUDY WISLOCKI as co -trustee <br />(hereinafter "Defendants"). Plaintiffs and Defendants are also collectively referred to as "the <br />Parties" herein or individually as a "Party." <br />WITNESSETH: <br />WHEREAS, the City is a city organized under the laws of the State of California, witha <br />duty and interest in protecting the public health, safety, and welfare within the city; and <br />WHEREAS, the Defendants are the current owner of property within Santa Ana, which <br />encompasses 904, 914, and 936 East 2nd Street, as well as two parcels without addresses, is <br />located on Assessor's Parcel Numbers (APN) 398-473-04, 398-473-08, 398-473-09, and 398- <br />473-12 (the "Property"); and <br />WHEREAS, RON STEVENS and JUDY WISLOCKI are the current trustees of the <br />CARL P. & MARION B. STEVENS TRUST (the "Trust"), but JAMES STEVENS, also served <br />as a Co -Trustee of the Trust from the death of MARION B. STEVENS on August 23, 2019, up <br />until his resignation on November 4, 2020, at which time JUDY WISLOCKI began serving as a <br />Co -Trustee; and <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 City of Santa Ana, et <br />al. v. CARL P. & MARION B. STEVENS TRUST, et al, Case No. 30-2020-01167808-CU-MC- <br />NJC (the "Action"). The City's complaint in the Action includes a prayer for injunctive relief, <br />civil penalties, attorneys' fees and costs, and other equitable relief against Defendants; and <br />WHEREAS, Defendants are the Co -Trustees of the Carl P. & Marion Stevens Trust (the <br />"Trust") and, as such Co -Trustees, intend to distribute the Property to a beneficiary of the Trust, <br />James Stevens. James Stevens intends to then transfer the Property to SIGNATURE SPORTS 1, <br />LLC, a California limited liability company ("Buyer"). Plaintiffs and Defendants further <br />understand (but do not represent) that Buyer intends to assume all liabilities and claims associated <br />with the Action and will bring the Property into compliance with State laws and City of Santa <br />Ana Municipal Codes; and <br />WHEREAS, this Agreement is conditioned on the Buyer obtaining title to the Property and <br />executing a Compliance Agreement (defined below) with the City; and <br />