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Docusign,Envelope ID:0CF3954D-0089-4C2A-B2C7-6EF99C030D33 N_2024-374 <br /> NOV 2 6 2024 <br /> D (:pto(0 <br /> Lash 1204(i '1(tc) <br /> SETTLEMENT AGREEMENT AND RELEASE <br /> This Settlement Agreement and Release ("Agreement") is entered into by and between <br /> CANDELARIO JALOMO (hereinafter referred to as "Plaintiff"), RAGER & YOON — <br /> EMPLOYMENT LAWYERS and MIZRAHI LAW, APC (collectively "Plaintiff & His <br /> Counsel"), on the one hand, and the CITY OF SANTA ANA (referred to as the "Defendant"), on <br /> the other(all collectively"the Parties"). <br /> RECITALS <br /> Plaintiff Candelario Jalomo filed this lawsuit on December 13, 2019. The Complaint alleged the <br /> following causes of action: 1) Violation of USERRA; 2) Violation of Military and Veterans Code <br /> section 394; 3) Military/Veteran Discrimination (FEHA); 4) Hostile Work Environment; and 5) <br /> Failure to Prevent Harassment, Discrimination, and/or Retaliation. <br /> On February 21, 2024, this matter went to verdict, and Plaintiff prevailed on his first and second <br /> causes of action for Violation of USERRA and Violation of Military & Veterans Code, § 394 et <br /> seq., and his third cause of action for Discrimination Based upon Military or Veteran Status. This <br /> entitled Plaintiff to seek attorney's fees and costs. <br /> By virtue of this Agreement, the Parties desire to settle fully and finally all controversies and <br /> differences arising out of or related to the Lawsuit and incidents described therein. <br /> The purpose of this Agreement is to globally settle and compromise Plaintiff's requests for <br /> attorney's fees and costs, which are the only remaining issues in the Lawsuit. This Agreement is <br /> to be signed by a duly authorized representative of the City of Santa Ana no later than December <br /> 3, 2024 at 12 p.m. <br /> 1 <br /> 52001888.1/006085.00028 <br />