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4. Following receipt of a copy of the Request for Dismissal with prejudice from Plaintiff dismissing this Action, the Trust through its insurer, will make available to Plaintiff two checks as follows: (a) a check in the amount of Seven Thousand Five Hundred Twenty -Nine Dollars and 27/100 cents ($7,529.27) made payable to "MARIA BAUTISTA AND LAW OFFICES OF MICHAEL FRANCIS SMITH"; and (b) a check in the amount of four hundred seventy dollars and 73/100 cents ($470.73) made payable to: "Department of Health Care Services." In total, the Trust will pay a total of $8,000 divided between the foregoing two checks in settlement of this Action. 5. The foregoing amounts to be paid by Defendants total Eighteen Thousand Dollars and no cents ($18,000.00) and represent the Defendants' fill and complete settlement of Plaintiff's claims for all damages alleged in the Action. The City will file the Request for Dismissal following confirmation that Plaintiff has received the checks from Defendants. 6. Plaintiff and Defendants agree that this Agreement constitutes frill and complete settlement of all claims made against Defendants in this Action. Plaintiff will not seek any further compensation for any other claimed damages, costs, or attorney's fees in connection with the matters encompassed in this Agreement. 7. Plaintiff acknowledges and agrees that Defendants have made no representations regarding the tax consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that he/she and he/she alone is liable for all taxes, if any, which are owed by him/her on any amount received hereunder including interest and penalties. Plaintiff will hold Defendants harmless from any and all claims made by federal, state, or local taxing authorities or lien holders against Plaintiff on amounts owed by her. 8. Plaintiff agrees that he/she and he/she alone will be responsible for any known or unknown liens for medical care related to, or arising from, the circumstances that gave rise to the Action. Plaintiff expressly agrees to hold Defendants harmless from any and all claims, if any, made by any lien holders against Plaintiff on amounts owed by him/her for any kind of medical care related to, or arising from, the circumstances that gave rise to the Action. 9. Plaintiff represents that, with the exception of this Action and the government tort claim associated therewith and submitted to the City of Santa Ana, he/she has not filed any complaints, claims, or actions against Defendants including any of its officers, agents, directors, supervisors, employees, or representatives of Defendants with any state, federal, or local agency or court and that he/she will not do so at any time hereafter as it relates to this Action and that if any agency or court assumes jurisdiction of any complaint, claim, or action against Defendants on Plaintiffs behalf, Plaintiff will direct that agency or court to withdraw and dismiss the matter with prejudice. 10. The Parties hereto hereby agree that all rights under Section 1542 of the Civil Code of the State of California are hereby waived. Civil Code Section 1542 provides as follows: "A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor." Page 2 of 5