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I N-2021-199 r NOWW NOT RE(uuNEU o WORK WAY PRO= DM OF OKIL SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims ("Agreement") is made and entered into by and between Leticia Romero ("Plaintiff'), and CITY OF SANTA ANA ("Defendant"). WITNESSE H: WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State California, Countyof Orange, Central Justice Center District known as LETICIA ROMERO v. CTIYOF SANTAANA et al., Case No. 30-2019-01114413-CU-PO-C7C (the "Action"). WHEREAS, Plaintiff and Defendant City of Santa Ana (collectively the "Parties"), desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described above. WHEREAS, the Parties agreed that the tentative settlement discussed below was conditioned on the Court's approval of the Defendant's Motion for Good Faith Settlement Determination (the "Motion"). The Court subsequently granted the Defendant's Motion on September 7, 2021. The Defendant filed and served notice of the ruling on September 13, 2021. Defendant, County of Orange, has until October 5, 2021 to file a petition for a writ of mandate for review of the Superior Court's ruling. NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and other good and valuable consideration, receipt of which is hereby acknowledged, and to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows: 1. This Agreement and compliance with this Agreement shall not be construed as an admission by Defendant of any liability whatsoever, or as an admission by Defendant of any violation of the rights ofPlaintiff or any person, violation of any order, law, statute, duty, or contract whatsoever against Plaintiff or any person. Defendant specifically disclaims any liability to Plaintiff or any other person for any alleged violation of the rights of Plaintiff or any person, or for any alleged violation of any order, law, statute, duty, or contract on the part of any employees or agents of Defendant. Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. 2. In settlement of this Action, Defendant will pay a total amount of Thirty Thousand Dollars ($30,000) to Plaintiff in the form of a check, made payable to "LETICIA ROMERO and her attorneys HUNT & ADAMS". The check will be made available on or after October 6, 2021, once it is determined whether Defendant, County of Orange, will seek a writ of mandate regarding the Court's ruling on the above Motion. 3. Each party must exchange a fully signed executed copy or original of this Agreement. Defendant cannot proceed with processing payment without a fully executed copy of the Agreement from Plaintiff. 4. Plaintiff will present Defendant with an executed copy of a Request for Dismissal form dismissing this Action with prejudice in exchange for the above check. Defendant will assume the Page 1 of 4