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INSURANCE NOT REQUIRED WORK MAY PROCEED CLERK OF COUNCIL N-2022-120 DATE: MAY ® 3 22 SETTLEMENT AGREEMENT I r AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims ("Agreement") is made and entered into by and between KATHY RADOS ("Plaintiff'), and CITY OF SANTA ANA ("Defendant"). WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State California, County of Orange, Central Justice Center District known as KATHY RADOS v. CITY OF SANTA ANA, et al., Case No. 30-2021-01206486 (the "Action"). WHEREAS, Plaintiff and Defendant (collectively, the "Parties"), desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described above. 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: l . 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 of Plaintiff 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. Each party will 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. 3. Following receipt of, or in exchange for, an executed copy of a Request for Dismissal form from Plaintiff dismissing this Action with prejudice, Defendant will make available a check in the amount of thirty-five thousand dollars and zero cents ($35,000) made payable "FLORES LAW GROUP APC AND KATHY RADOS". Defendant will file the Request for Dismissal following receipt of the foregoing check by Plaintiffs counsel. This monetary amount represents a full and complete settlement of Plaintiffs claims for all damages alleged in the Action. 4. Plaintiff agrees that this Agreement constitutes full and complete settlement of all claims made against Defendant 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. Page 1 of