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Docusign Envelope ID;9CBEDCE3-696B-4C55-9FC6-3ABDE9663BF9 <br /> 2.4 "Claims" <br /> "Claim" or "Claims" shall mean any past or present, fixed or contingent, <br /> mature or immature, liquidated or unliquidated, claims, cross-claims, <br /> liabilities, rights, demands, notices, inquiries, damages, requests, suits, <br /> lawsuits, costs, costs of suit, attorneys' fees, experts' fees, administrative <br /> proceedings, causes of action, orders, of any nature, character, type or <br /> description, whenever and however occurring, whether at law or equity, <br /> directly related to the Action. <br /> 2.5 "CUPs" <br /> "CUPS" shall mean the conditional use permits associated with the <br /> Property as defined in Section 2.9 below. These permits are CUP 7I-22, CUP <br /> 72-20, CUP 74-6. <br /> 2.6 "Effective Date" <br /> "Effective Date" of this Agreement shall mean the date of the last <br /> signature necessary to execute this Agreement. <br /> 2.7 "Notice and Order" <br /> "Notice and Order" shall mean the "Notice and Order to Repair and <br /> Abate Public Nuisance" the City issued to Bruce Metal on February 27, 2024. <br /> 2.8 "Party" or "Parties" <br /> "Party" or "Parties" shall mean the City of Santa Ana, Lawrence M. <br /> Kuda, Jr., as Trustee of the Kuda Family Surviving Grantors Trust, and <br /> Bruce Metal and Salvage, Inc. <br /> SETTLEMENT AGREEMENT <br /> 2 <br /> 73158250v1 <br />