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MORALES GUERRERO, JESUS
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MORALES GUERRERO, JESUS
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Last modified
11/17/2023 3:32:27 PM
Creation date
11/17/2023 3:20:11 PM
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Contracts
Company Name
MORALES GUERRERO, JESUS
Contract #
A-2023-199
Agency
City Attorney's Office
Council Approval Date
11/7/2023
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A-2023-199 <br />Nov 1 7 �U13 <br />L Ne ��ni <br />SETTLEMENT AGREEMENT <br />AND RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release of All Claims ("Agreement") is made and entered <br />into by and between JESUS MORALES GUERRERO ("Plaintiff'), and CITY OF SANTA <br />ANA and MICHAEL CLABORN (collectively, "Defendants"). <br />WITNF.SSETH: <br />WHEREAS, Plaintiff filed an action against Defendants in the Superior Court of the State <br />California, County of Orange, Central Justice Center known as JESUS MORALES GUERRERO v. <br />CITY OF SANTAANA, et al., Case No. 30-2021-01223509-CU-PA-CJC (the "Action"). <br />WHEREAS, Plaintiff and Defendants (collectively, the "Parties"), desire to settle fully <br />and finally all differences between them, including, but in no way limited to, those differences <br />described above. <br />NOW, THEREFORE, in consideration of the mutual covenants and promises herein <br />contained and other good and valuable consideration, receipt of which is hereby acknowledged, and <br />to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows: <br />1. This Agreement and compliance with this Agreement shall not be construed as an <br />admission by Defendants of any liability whatsoever, or as an admission by Defendants of any <br />violation of the rights of Plaintiff or any person, violation of any order, law, statute, duty, or contract <br />whatsoever against Plaintiff or any person. Defendants specifically disclaim any liability to <br />Plaintiff or any other person for any alleged violation of the rights of Plaintiff or any person, or for <br />any alleged violation of any order, law, statute, duty, or contract on the part of any employees or <br />agents of Defendants. Likewise, this Agreement and compliance with this Agreement shall not be <br />construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. <br />2. Each party will exchange a fully signed executed copy or original of this <br />Agreement. Defendants cannot proceed with processing payment without a fully executed copy of <br />the Agreement from Plaintiff. <br />3. Following receipt of, or in exchange for, an executed copy of a Request for <br />Dismissal form from Plaintiff dismissing this Action with prejudice, Defendants will make <br />available a check in the amount of Five Hundred and Seventy -Five Thousand Dollars <br />($575,000.00) made payable "JESUS MORALES GUERRERO AND YAGOUBZADEH LAW <br />FIRM LLP." This amount represents a full and complete settlement of Plaintiffs claims for all <br />damages alleged in the Action. The City of Santa Ana will file the Request for Dismissal following <br />receipt of the foregoing check by Plaintiffs counsel. <br />4. Plaintiff and Defendants agree that this Agreement constitutes full and complete <br />settlement of all claims made against Defendants in this Action. Plaintiff will not seek any <br />further compensation for any other claimed damages, costs, or attorney's fees in connection with <br />the matters encompassed in this Agreement. <br />5. Plaintiff acknowledges and agrees that Defendants have made no representations <br />Page 1 of 4 <br />
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