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Automated Clearing; House ("ACII") transfer to the account in the name of the Plaintiff designated by the Plaintiff in writing or by mailing; a check nnade payable to Anchor Stone Christian Church to Plaintiffs counsel at the address listed. below in Section 20. Plaintiff agrees to Provide all paperwork reasonably necessary to process such payment including but not limited to a W-9. v. Following Plaintiffs receipt of a CUP for use of the Property for community assembly as a church and within five (5) days of Plaintiff's receipt of the funds as set forth. above in Section 3(e)(iv) the Parties agree to gale a joint stipulation for dismissal with prejudice of the Action. 4. Plaintiff and Defendants agree that this Agreement, the consummation of the actions set forth in Section 3, and all payments made pursuant thereto will constitute full and complete settlement of all claims made against Defendants in this Action. Plaintiff agrees that, except as contemplated by this Agreement, upon consummation of the actions set forth in Section 3, including receipt of the payment set forth in Section 3(e)(iv), Plaintiff will not seek any further compensation from the Defendants for ally other claimed damages, costs, or attorney's fees in connection with the Action or the matters encompassed in this Agreement. 5. Plaintiff acknowledges and agrees that Defendants have made no representations regarding the tax consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that they and they alone are liable for all taxes, if any, which are owed by them on ally amount received hereunder including interest and penalties. Plaintiff agrees to hold Defendants harmless fiom any and all claims made against the Defendants by federal, state, or local taxing authorities with respect to amounts owing by Plaintiff as a result of any amount received by the Plaintiff hereunder. G. Separate and apart from tax liens, Plaintiff'agrees to hold the City harmless from any and all lien holders of any kind, to whom Plaintiff or their attorneys are indebted. Plaintiff further acknowledges that they and not the City are responsible for compromising any liens related to, or arising, from, this action. 7. Plaintiff represents that, with the exception of the Action and any government tort claim associated therewith and submitted to the City of Santa Ana,Plaintiff has not filed any complaints, claims, or actions related to the Action against Defendants including any of their officers, agents,directors, supervisors,employees, or rQpresentatives of Defendants with any state, federal,or local agency or court and that Plaintiff will not do so at any time hereafter as it relates to the Action except as necessary to enforce this Agreement, and that if any agency or court assumes jurisdiction of any complaint, claim, or action against Defendants on Plaintiff's behalf related to the Action, other than a complaint, claim, or action necessary to enforce this Agreement, Plaintiff will direct that agency or court to withdraw and dismiss the matter with prejudice. 8. The Parties hereby agree that all rights under Section 1542 of the Civil Code of the State of California are hereby waived. Civil Cock Section 1542 provides as follows: Page 3 of 6 (Representative of Plaintiff,Initials)