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Vinesign Document ID: 25481510-1 CEF-4D8F-989B-AFOC79DC17CO N-2025-092 <br /> HCURJIINCE iKT REQUIRED <br /> iKORK PROCFFD <br /> CITY CLEfWPR 14 2025 <br /> DUE: SETTLEMENT AGREEMENT AND <br /> RELEASE OF ALL CLAIMS <br /> This Settlement Agreement and Release of All Claims(hereinafter "Agreement") is made <br /> jo fiAm 14�0 and entered into by and between MIGUEL ANGEL MORAN (hereinafter "Plaintiff'), and <br /> &W I9AAUo 44) the CITY OF SANTA ANA (hereafter"Defendant"). <br /> WITNESSETH: <br /> WHEREAS,Plaintiff filed an action against Defendant in the Superior Court of the State <br /> California,County of Orange,Central Justice Center known as MIGUEL ANGEL MORAN v.CITY <br /> OF SANTA ANA,et al., Case No. 30-2022-01297525 (the"Action"). <br /> WHEREAS, Plaintiff and Defendant (collectively, the "Parties"), desire to settle fully <br /> and finally all differences between them, including, but in no way limited to, those differences <br /> described above. <br /> NOW, THEREFORE, in consideration of the mutual covenants and promises herein <br /> contained and other good and valuable consideration, receipt of which is hereby acknowledged, <br /> and to avoid unnecessary litigation, it is hereby agreed by and between the Parties as follows: <br /> 1. This Agreement and compliance with it shall not be construed as an admission by <br /> Defendant of any liability whatsoever, or as an admission by Defendant of any violation of the <br /> rights of Plaintiff or any person, violation of any order, law, statute, duty, or contract whatsoever <br /> against Plaintiff or any person. Defendant specifically disclaims any liability to Plaintiff or <br /> any other person for any alleged violation of the rights of Plaintiff or any person,or for any alleged <br /> violation of any order, law, statute, duty, or contract on the part of any employees or agents of <br /> Defendant. Likewise, this Agreement and compliance with it shall not be construed as an <br /> admission by Plaintiff of any liability,misconduct, or wrongdoing whatsoever. <br /> 2. Each party will exchange a fully signed executed copy or original of this <br /> Agreement. Defendant cannot process payment without a fully executed copy of the Agreement <br /> from Plaintiff. <br /> 3. In settlement of this action,Defendant will pay a total amount of Twelve Thousand <br /> dollars and no cents ($12,000) to "MIGUEL ANGEL MORAN AND DOWNTOWN LA LAW <br /> GROUP". This amount represents a full and complete settlement of Plaintiffs claims for all damages <br /> alleged in the Action against Defendant only. Defendant will file the Request for Dismissal following <br /> Plaintiffs receipt of the settlement check. Plaintiff agrees that this Agreement constitutes full and <br /> complete settlement of all claims made against Defendant in this Action. Plaintiff will not seek <br /> any further compensation for any other claimed damages, costs, or attorney's fees in connection <br /> with the matters encompassed in this Agreement. <br /> 4. Plaintiff acknowledges and agrees that Defendant have made no representations <br /> regarding the tax consequences of any amounts received pursuant to this Agreement. Plaintiff <br /> agrees that he/she and he/she alone is liable for all taxes, if any, which are owed by his/her on <br /> Page l of 4 <br /> The signed document can be validated at https://app.vinesign.com/Verify <br />