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INSURANCE NOT REQUIRED A 2p23_238
<br />WORK MAY PROCEED
<br />CITY CLERK
<br />DATE:
<br />SETTLEMENT AGREEMENT
<br />Q: CAV W) \\ AND RELEASE OF ALL CLAIMS
<br />CA� �l� t�ac Tfiis Settlement Agreement and Release of All Claims "Agreement' is made and entered into by
<br />and between ANTHONY A. GONZALEZ, ANGELICA GONZALEZ, ANASTASIA GONZALEZ, a
<br />minor by and through her Guardian Ad Litem, Anthony A. Gonzalez, AUGUSTIS GONZALEZ, a minor
<br />by and through his Guardian Ad Litem, Anthony A. Gonzalez, AND ADELINE GONZALEZ, a minor by
<br />N and through her Guardian Ad Litem Anthony A. Gonzalez (collectively, "Plaintiffs"), and CITY OF
<br />SANTA ANA (`Defendant').
<br />Q
<br />WITNESSETH:
<br />WHEREAS, Plaintiffs filed an action against Defendant in the Superior Court of the State of
<br />California, County of Orange, Center Justice Center District known as ANTHONY A. GONZALEZ, ET
<br />AL., v. CITY OF SANTA ANA, Case No. 30-2022-01284596-CU-PA-NJC (the "Action").
<br />WHEREAS, Plaintiffs and Defendant (collectively, the "Parties"), desire to settle fully and finally
<br />all differences between them, including, but in no way limited to, those differences described above.
<br />NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained
<br />and other good and valuable consideration, receipt of which is hereby acknowledged, and to avoid
<br />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 Defendant of any liability whatsoever, or as an admission by Defendant of any violation of
<br />the rights of Plaintiffs or any person, violation of any order, law, statute, duty, or contract whatsoever
<br />against Plaintiffs or any person. Defendant specifically disclaim any liability to Plaintiffs or any other
<br />person for any alleged violation of the rights of Plaintiffs or any person, or for any alleged violation of any
<br />order, law, statute, duty, or contract on the part of any employees or agents of Defendant. Likewise, this
<br />Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiffs of
<br />any liability, misconduct, or wrongdoing whatsoever.
<br />2. Each party will exchange a fully signed executed copy or original of this Agreement.
<br />Defendants cannot proceed with processing payment without a fully executed copy of the Agreement from
<br />Plaintiff.
<br />3. Following receipt of, or in exchange for, an executed copy of a Request for Dismissal form
<br />from Plaintiffs dismissing this Action with prejudice, Defendants will make available fives checks that
<br />total Eighty -Seven Thousand Dollars ($87,000.00). Defendant agrees to pay the sum in the following
<br />manner:
<br />• "ANTHONY A. GONZALEZ AND LAW OFFICES OF WILLIAM W. GREEN &
<br />ASSOCIATES," in the amount of $52,000.
<br />• "ANGELICA GONZALEZ AND LAW OFFICES OF WILLIAM W. GREEN &
<br />ASSOCIATES," in the amount of $20,300,
<br />• "AUGUSTIS GONZALEZ by and through his Guardian Ad Litem ANTHONY A.
<br />GONZALEZ AND LAW OFFICE OF WILLIAM W. GREEN & ASSOCIATES," in the
<br />amount of $4,900.
<br />• "ANASTASIA GONZALEZ by and through her Guardian Ad Litem ANTHONY A.
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