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INSllWCE NOT REQUIRED A_2025-113 WfORK MAY PROCEED UTY CLERK DATE JUL 15 2075 o:C,AC (�) SETTLEMENT AGREEMENT Dtsv+a 4vintana(01) AND RELEASE OF CLAIMS This Settlement Agreement and Release of Claims ("Agreement") is made and entered into by and between ANCHOR. STONE CHRISTIAN CHURCH, a California non-profit religious corporation ("Plaintiff'), and CITY OF SANTA ANA also served and sued as SANTA ANA CITY COUNCIL (collectively, "City" or"Defendants"). ITNESSETH: WHEREAS, Plaintiff filed an action against Defendants in the United States District Court for the Central District of California, Southern Division known as ANCHOR STONE CHRISTIAN Cl ILIRCH v. CITY OF SANTA ANA,et al., Case No. 8:25-cv-215 (the "Action"). WHEREAS, Plaintiff and Defendants (collectively, the "Parties"), desire to settle fully and finally all differences between them related to the claims asserted by Plaintiff in the Action. NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and other good and valuable consideration. receipt and sufficiency 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 this Agreement 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 disclaim 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 Defendants. Likewise, this Agreement and compliance with this Agreement shall not be construed as commentary by Plaintiff on the validity or strength of its claims, nor as an admission as to liability, misconduct, or wrongdoing whatsoever. 2. The Parties hereby acknowledge that Defendants cam-lot proceed with processing payment without a frilly executed copy of the Agreement from Plaintiff and agree to exchange a frilly signed and executed copy or original of this Agreement. 3. The Plaintiff and Defendants hereby agree to settle the Action on the following terms: a. Plaintiff will resubmit its application to the City for a Conditional Use Permit ("CUP") for use of the property at 2938 Daimler Street in Santa Ana (the "Property") for community assembly as a church (the "CUP Application") and may simultaneously (or later) submit required plan checks and permit applications for Plaintiff's planned renovations of the building on the Property. Page I of 6 (Representative of Plaintiff, Initials)