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DocuSign Envelope ID: 8Cl D02l6-78F2-4859-AADO-CF3AO7366EED INSURANCE NOT REQUIRED WORK MAY PROCEED CITY CLERK N DM- 0 N ea CV SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS N-2023-157 This Settlement Agreement and Release of All Claims ("Agreement") is made and entered into by and between DEANNA KERYLOW ("Plaintiff'), and CITY OF SANTA ANA (� j ("Defendant"). o'�ko(K�� /�J�Sµ>� WITNESSETH: WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State California, County of Orange, Central Justice Center District known as DEANNA KERYLOW v. CITY OF SANTA ANA, Case No. 30-2021-01226130-CU-PO-NJC (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: 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 anyperson, 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 with prejudice of the Action, Defendant will make available to Plaintiff a check in the amount of forty-five thousand dollars ($45,000.00) made payable to "DEANNA KERYLOW AND GIBSON & HUGHES." Defendant will file the Request for Dismissal following Plaintiffs counsel's receipt of the foregoing check. 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