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5, Plaintiffaclahowledges and agrees that Defendant has made no representations regarding
<br />the tax consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that .she
<br />and she alone is liable for all taxes, if any, which are owed by heron any amotmt received hereunder
<br />including interest and penalties. Plaintiff will hold Defendant harmless from any and all claims made by
<br />federal, state, or local taxing authorities or lien holders of any kind, including liens for worker's
<br />compensation payments, disability payments, medical care or medical expenses, against Plaintiff for
<br />amounts owed by her.
<br />a. Plaintiff specifically acknowledges that Orange County Superior Court tiled a
<br />"Notice of Lien" in this Action and claims a lien against any settlement proceeds. Plaintiff further
<br />acknowledges that she, and she alone, is responsible for compromising this lien in addition to any
<br />other liens ZiPlaintiff's
<br />her in relation to this Action and the events that gave rise to this Action.
<br />Initials
<br />6. Plaintiff represents that, with the exception of this Action and the government tort claim
<br />associated therewith and submitted to Defendant, she has not filed any other complaints, claims, or
<br />actions against Defendant including any of its officers, agents, directors, supervisors, employees, or
<br />representatives of Defendant with any state, federal, or local agency or court and that she will not do so
<br />at any time hereafter as it relates to this Action and that if any agency or octal assumes jurisdiction of
<br />any complaint, claim, or action against Defendant on Plaintiffs behalf, Plaintiff will direct that agency
<br />or court to withdraw and dismiss the matter with prejudice.
<br />7. The Patties hereto hereby agree that all rights under Section 1542 of the Civil Code of the
<br />State of California are hereby waived. Civil Code Section 1542 provides as follows:
<br />"A general release does not extend to claims which the creditor does not know or
<br />suspect to exist in his or her favor at the time of executing the release, which if
<br />known by him or her must have materially affected his or her settlement with the
<br />debtor."
<br />8. Notwithstanding the provisions of Civil Code section 1542, each party hereby
<br />irrevocably and unconditionally releases and forever discharges each other party and each arid all of its
<br />officers, agents, directors, supervisors, employees, representatives, and its successors and assigns and
<br />al I persons acting by, through, under, or in concert with each other party from any and all charges,
<br />complaints, claims, and liabilities ofany kind or nature whatsoever, known or unknown, suspected or
<br />unsuspected (hereinafter referred to as "claim" or "claims") which each releasing petty at any time
<br />heretofore had or claimed to have or which each releasing patty at any time hereafter may have or claim
<br />to have, incidental to the incident(s) which form the basis of the Action.
<br />9. Each person signing below represents that site has reviewed all aspects of this Agreement,
<br />that the Agreement has been carefully read and fully explained to them and that they understand every
<br />provision of this Agreement, that they understand that in agreeing to this document they are releasing
<br />each party hereby from any and all claims they may have against each party released, that they
<br />voluntarily agree to all the terms set forth in this Agreement, that they knowingly and willingly
<br />intend to be legally bound by the same, that they were given the opportunity to consider the terms
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