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A-2025-093 INSURMCE NOT REQUIRED WORK WAY PROCEED CITY CLERIC DATE- JUL 0 l 2025 SETTLEMENT AGREEMENT NT AND l l� �io RELEASE OF ALL CLAIMS u This Settlement Agreement and Release of All Claims(hereinafter"Agreement") is made and entered into by and between WENDY BARAJAS (hereinafter "Plaintiff'), and the CITY OF SANTA ANA and ROLAND ANDRADE(hereafter"Defendants"). VLL_T WHEREAS,Plaintiff filed an action against Defendants in the Superior Court of the State California, County of Orange, Central Justice Center known as WENDY BARMAS v. CITY OF SAVI A ANA,et al., Case No. CIVRS2401844(the "Action"). WHEREAS, Plaintiffand Defendants (collectively, the "Parties"), desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described above. I 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: I. This Agreement and compliance with it shall not be construed as an admission by Defendants of any liability whatsoever, or as an admission by Defendants of any violation of the rights of Plaintiff or any person,violation of any order,law,statute,duty,or contract whatsoever against Plaintiff or any person. Defendants specifically disclaims any liability to Plaintiff or any other person for any alleged violation of the rights of Plaintiff 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 Defendant. Likewise, this Agreement and compliance with it shall not be construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. 2. Each party will exchange a fully signed executed copy or original of this Agreement. Defendants cannot process payment without a fully executed copy of the Agreement from Plaintiff. 3. Following receipt of, or in exchange for, an executed copy of a Request for Dismissal form From Plaintiff dismissing the Action with preiudice, Defendants will make available a check in the amount of One Hundred Fifteen Thousand dollars and no cents($115,000) made payable "WENDY BARAJAS AND LAVA OFFICES OF GREGORY A. YATES". This amount represents a full and complete settlement of Plaintiff's claims for all damages alleged in the Action. Defendants will file the Request for Dismissal following Plaintiffs receipt and confirmation of the settlement check. Plaintiff agrees that this Agreement constitutes full and complete settlement of all claims made against Defendants in this Action. Plaintiff will not seek ally further compensation for any other claimed damages, costs, or attomey's fees in connection with the matters encompassed in this Agreement. 4. Plaintiff acknowledges and agrees that Defendants have made no representations regarding the tax consequences of any amounts received pursuant to this Agreement. Plaintiff Page 1 of 4