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DocuSign Envelope ID:4ADBBC53-305C-4022-BA5E-84BC83F75552 A-2024-049 <br />APR 19 2674 <br />p•. }o C¢) SETTLEMENT AGREEMENT AND RELEASE <br />This Settlement Agreement and Release ("Settlement Agreement") is made by and between <br />Plaintiffs Mayra Mendoza and Giovanni Mendoza, ("Plaintiffs"), and Defendant City of Santa Ana <br />("City"), Officer Matthew Thomas and their agents, employees, attorneys, representatives, <br />successors, and assigns, (collectively "City Defendants"). (Plaintiffs and City Defendants may be <br />collectively referred to as "Settling Parties") in connection with the case entitled Maym Mendoza, et <br />al vs. City of Santa Ana, et al, filed in the Superior Court of the State of California for the County of <br />Orange, Case No. 30-2020-01147294-CU-PA-CJC.. <br />RECITALS <br />This action was brought by Plaintiffs alleging personal injuries sustained on July 12, 2019 <br />as the result of an automobile accident as described in their complaint referenced above. All <br />representations, agreements, promises and other acts recited on behalf of Plaintiffs are intended to <br />and do refer to Plaintiffs Mayra Mendoza and Giovanni Mendoza. <br />agreed: <br />NOW THEREFORE, in consideration of the foregoing promises set forth below, it is <br />1.0 SETTLEMENT TEAMS. - <br />The settlement terms entered into between the Settling Parties on the pending matter <br />are as follows: <br />• City Defendants will pay to Plaintiff Mayra Mendoza the total sum of Two Hundred <br />and Fifteen Thousand dollars ($215,000.00), in full and final settlement of any and all <br />claims by said Plaintiff against City Defendants, which includes attorney's fees, costs <br />and liens, to be dispersed as follows: <br />• Said sum of Two Hundred and Fifteen Thousand dollars ($215,000.00) to be paid to <br />Plaintiff Mayra Mendoza and her attorneys Avrek Law Firm. <br />• City Defendants will pay to Plaintiff Giovanni Mendoza the total sum of Five <br />Thousand dollars ($5,000.00), in full and final settlement of any and all claims by said <br />Plaintiff against City Defendants, which includes attorney's fees, costs and liens, to <br />be dispersed as follows: <br />• Said sum of Five Thousand dollars ($5,000.00) to be paid to Plaintiff Giovanni <br />