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A-2024-185 OCi 1 201.4 O CAo C49) csare. \J,1\,Uvv,s SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims ("Agreement") is made and entered into by and between PIERCE PEIFFER("Claimant") and CITY OF SANTA ANA, ("City"). WITNESSETH: WHEREAS, Plaintiff PIERCE PEIFFER filed a government tort Claim Against the City of Santa Ana, Claim No. 2024-135 (the"Peirce Peiffer Claim"). WHEREAS, Claimant and City (collectively, the "Parties"), desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described in the Pierce Peiffer Claim. NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and other good and valuable consideration,receipt of which is hereby acknowledged,and to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows: 1. This Agreement and compliance with this Agreement shall not be construed as an admission by City of any liability whatsoever, or as an admission by City of any violation of the rights of Claimant or any person,violation of any order,law,statute,duty,or contract whatsoever against Claimant or any person. City specifically disclaims any liability to Claimant or any other person for any alleged violation of the rights of Claimant or any person, or for any alleged violation of any order, law, statute, duty, or contract on the part of any employees or agents of City. Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by City of any liability,misconduct, or wrongdoing whatsoever. Each party will exchange a fully signed executed copy or original of this Agreement. City cannot proceed with processing payment without a fully executed copy of the Agreement from Claimant. Following receipt of a fully signed executed copy or original of this Agreement and receipt of an executed W- 9 form, City will make available a check in the amount of Two Hundred and Twenty-Five Thousand($225,000) made payable to "Pierce Peiffer and MANLY STEWART&FINALDI". Claimant acknowledges and agrees that settlement payment shall be made payable no later than twenty(20) days after Claimant delivers his executed Agreement to the City. Claimant agrees that this Agreement constitutes full and complete settlement the Pierce Peiffer Claim against the City and Santa Ana Police Officers. Claimant will not seek any further compensation for any other claimed damages, costs, or attorney's fees in connection with the matters encompassed in this Agreement. Claimant specifically and expressly acknowledges that this settlement will forever waive the Claimant's ability to file a lawsuit regardin (legations raised in, or related to,the Pierce Peiffer Claim. (Claimant's Initials) 2. Claimant acknowledges and agrees that City has made no representations regarding the tax consequences of any amounts received pursuant to this Agreement. Claimant agrees that he and he alone is liable for all taxes, if any, which are owed by Claimant on any amount received hereunder including interest and penalties. Claimant will hold City harmless from any and all claims made by federal, state, or local taxing authorities or lien holders against Claimant on amounts owed by them. Page 1 of 4