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<br />APR 0 9 2024 RELEASE OF ALL CLAIMS N-2024-131
<br />In regard to Maria Ramirez v. City of Santa Ana, Orange County Superior Court Case No. 30-2021-01237194-CU-
<br />PO-CJC (the "Action"), Maria Ramirez (`Plaintiff'), being of lawful age of 18 years or older, agrees and understands
<br />that in settlement of the foregoing lawsuit, the City of Santa Ana ("the City") will agree to pay Plaintiff the sum of
<br />Fifty Thousand Dollars ($50,000) and no cents.
<br />In exchange for payment by the City, Plaintiff does hereby for himself/herself and for his/her heirs, executors,
<br />administrators, successors and assigns, release, acquit and forever release and discharge the City of Santa Ana and
<br />its representatives, heirs, executors, administrators, trustees, successors, affiliates, subrogoes, subrogees, assignors,
<br />assignees, subsidiaries, parent corporations, agents, employees, officers, directors, attorneys, council members,
<br />firms, associations, and insurers (hereafter collectively the "City Parties") from any and all claims, actions, demands,
<br />rights, damages, costs, loss of service, expenses and compensation whatsoever, which the Plaintiff now has or which
<br />may hereafter accrue on account of or in any way growing out of any and all known and unknown, foreseen and
<br />unforeseen bodily or personal injuries and property damage and the consequences thereof resulting from the trip and
<br />fall accident that occurred on or about January 14, 2020 near 1110 South Garnsey Street in Santa Ana, California as
<br />alleged in the Action. Plaintiff further acknowledges that she is responsible for all medical bills or liens for medical
<br />services related in any way to the subject of the Action and that to her knowledge, there are no asserted liens or
<br />monies owed to Medicare or Medi-Cal.
<br />It is understood and agreed that this settlement is the compromise of the Action, a disputed matter, and that this
<br />settlement is not to be construed as an admission of liability on the part of the City.
<br />It is further understood and agreed that all rights under Section 1542 of the California Civil Code and any similar
<br />law of any state or territory of the United States are hereby expressly waived. Section 1542 reads as follows:
<br />A general release does not extend to claims which the creditor does not know or suspect to exist in his
<br />or her favor at the time of executing the release, which if known by him or her must have materially
<br />affected his or her settlement with the debtor.
<br />Plaintiff hereby declares and represents that the bodily injuries/property damage or other injuries sustained are / or
<br />may be permanent and progressive and that recovery therefrom is uncertain and indefinite and in making this Release
<br />it is understood and agreed, that the Plaintiff relies wholly upon the Plaintiff s judgment, belief and knowledge of
<br />the nature, extent, effect, and duration of said injuries and liability therefore and is made without reliance upon any
<br />statement or representation of the City or any of the parties hereby released or their representatives or by any
<br />physician or surgeon employed by them. Plaintiff acknowledges she is represented by counsel in the Action and the
<br />terms of this Release have been relayed to her by a means she understands.
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<br />Plaintiff further declares and represents that no promise, inducement or agreement not expressed in this Release has
<br />been made to her, and that this Release contains the entire agreement between the parties to this Release, and that
<br />the terms of this Release are contractual and not a mere recital. Plaintiff and the City intend to be bound by the
<br />terms of this Release.
<br />Plaintiff agrees and represents that on the date below, he/she was not hospitalized or in a medical facility nor was
<br />he/she admitted to a medical facility within the past 15 days. Signed on 2 1 day of March 2024
<br />Plaintiff— Maria Ramirez
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