CARL P. & MARION B. STEVENS TRUST

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