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GONZALEZ AND LAW OFFICE OF WILLIAM W. GREEN & ASSOCIATES," in the <br />amount of $4,900. <br />® "ADELINE GONZALEZ by and through her Guardian Ad Litem ANTHONY A. <br />GONZALEZ AND LAW OFFICE OF WILLIAM W. GREEN & ASSOCIATES," in the <br />amount of $4,900. <br />These amounts represent a full and complete settlement of Plaintiffs' claims for all damages alleged <br />in the Action. The City of Strata Ana will file the Request for Dismissal following receipt of the foregoing <br />checks by Plaintiffs' counsel. <br />4l. Plaintiffs and Defendant agree that this Agreement constitutes full and complete settlement <br />of all claims made against Defendants in this Action. Plaintiffs will not seek any further compensation for <br />any other claimed damages, costs, or attorney's fees in connection with the matters encompassed in this <br />Agreement. <br />5. Plaintiffs acknowledge and agree that Defendant have made no representations regarding <br />the tax consequences of any amounts received pursuant to this Agreement. Plaintiffs agree that they and <br />they alone are liable for all taxes, if any, which are owed by them on any amount received hereunder <br />including interest and penalties. Plaintiffs will hold Defendant harmless from any and all claims made by <br />federal, state, or local taxing authorities or lien holders against Plaintiffs on amounts owed by them. <br />6. Plaintiffs represent that, with the exception of this Action and the government tort claim <br />associated therewith and submitted to the City of Santa Ana, they have not filed any complaints, claims, or <br />actions against Defendant including any of their officers, agents, directors, supervisors, employees, or <br />representatives of Defendant with any state, federal, or local agency or court and that they will not do so at <br />any time hereafter as it relates to this Action and that if any agency or court assumes jurisdiction of any <br />complaint, claim, or action against Defendant on Plaintiffs' behalf, Plaintiffs will direct that agency or <br />court to withdraw and dismiss the matter with prejudice. <br />7. The Parties 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 suspect to <br />exist in his or her favor at the time of executing the release, which if known by him or her <br />most have materially affected his or her settlement with the debtor." <br />8. Notwithstanding the provisions of Civil Code section 1542, each party hereby irrevocably <br />and unconditionally releases and forever discharges each other party and each and all of its officers, <br />agents, directors, supervisors, employees, representatives, and its successors and assigns and all persons <br />acting by, through, under, or in concert with each other party from any and all charges, complaints, claims, <br />and liabilities of any kind or nature whatsoever, known or unknown, suspected or unsuspected (hereinafter <br />referred to as "claim" or "claims") which each releasing party at any time heretofore had or claimed to <br />have or which each releasing party at any time hereafter may have or claim to have, incidental to the <br />incident(s) which form the basis of the Action. <br />9. Each person signing below represents that he/she has reviewed all aspects of this <br />Agreement, that the Agreement has been carefully read and fully explained to them and that they <br />understand every provision of this Agreement, that they understand that in agreeing to this document they <br />are releasing each party hereby from any and all claims they may have against each party released, that <br />Page 2 of 5 <br />