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DocuSign Envelope ID: A5414ED5-93ED-4AAA-A317-1ABE1 FC7AFIF
<br />SETTLEMENT AGREEMENT AND
<br />RELEASE OF ALL CLAIMS
<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/or "Petitioner"), and JEANNE M. MUNSELL, an individual
<br />(hereinafter, "Property Owner" and/or "Respondent Munsell"). Petitioner and Respondent
<br />Munsell are also collectively referred to as "the Parties" herein or individually as a "Party."
<br />WITNESSETH:
<br />WIIEREAS, the City is a city organized under the laws of the State of California, with a
<br />duty and interest in protecting the public health, safety, and welfare within the city; and
<br />WHEREAS, Respondent Munsell is the current owner of property located at 930 N.
<br />Dianne Street, Santa Ana, California 92701, identified as Assessor's Parcel Number 400-163-13
<br />(the "Property"); and
<br />WHEREAS, on December 2, 2021, the City filed a receivership petition against the
<br />property owner, JEANNE M. MUNSELL (hereinafter "Respondent Munsell" and/or "Property
<br />Owner"), and the following parties: BANK OF AMERICA, NATIONAL ASSOCIATION, a
<br />national banking association; OCWEN LOAN SERVICING, LLC, Delaware Limited Liability
<br />Company; SELECT PORTFOLIO SERVICING, INC., a Utah Corporation; DEUTSCHE BANK
<br />NATIONAL TRUST COMPANY, AS TRUSTEE, IN TRUST FOR THE REGISTERED
<br />HOLDERS OF MORGAN STANLEY ABS CAPITAL I INC. TRUST 2006-HE6, MORTGAGE
<br />PASS THROUGH CERTIFICATES, SERIES 2006-HE6, a national banking association,
<br />SOLAR CITY CORPORATION, a Delaware Corporation; TESLA, INC.; a Delaware
<br />Corporation (hereinafter collectively referred to as "Respondents"), in the Superior Court of the
<br />State California, County of Orange, Central Justice Center District known as CITY OF SANTA
<br />ANA V. JEANNE M. MUNSELL, et al., Case No. 30-2021-01234505-CU-PT-CJC (the
<br />"Action"). The City's Action in this petition includes a prayer for the Court to appoint a
<br />receiver to take possession and control of the Property pursuant to California Health & Safety
<br />section 17980.7(c) and bring the Property into compliance with the law, attorneys' fees and costs,
<br />and for other equitable relief against Respondents;
<br />WHEREAS, SERGIO BECERRA CASILLAS, an individual ("Buyer"), intends to
<br />acquire the Property from the Property Owner, will assume all liabilities and claims associated
<br />with the Action and will bring the Property into compliance with State laws and City of Ana
<br />Municipal Codes; and
<br />WHEREAS, Buyer has agreed, by executing a Compliance Agreement (as defined in
<br />paragraph 2 below), to pay the City's staff time, reasonable attorney's fees, and abatement costs
<br />as a result of this Action; and
<br />WHEREAS, this Agreement is conditioned on the Buyer obtaining title to the Property and
<br />executing a Compliance Agreement (as defined below) with the City; and
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