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INSURANCE NOT REQUIRED A-2025-115 WORK f�P+Y P'ROCUD GITY CLERK DATE: JUL 16 2025 D:LA D(fF) Kvit Neitax-/ SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made and entered into on this 16th day of July, 2025, by and between ARCH INSURANCE COMPANY(hereinafter "Plaintiff"), and the CITY OF SANTA ANA (hereafter"Defendant"). WITNESSETH: WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State California, County of Orange, Central Justice Center known as ARCH INSURANCE COMPANY v. CITY OF SANTAANA, Case No. 30-2024-01436141-CU-BC-CJC (the"Action"). WHEREAS, Plaintiff and Defendant (collectively, the "Parties"), desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described above. 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: 1. This Agreement and compliance with it shall not be construed as an admission by Defendant of any liability whatsoever, or as an admission by Defendant 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. Defendant 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. Defendant 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 prejudice, Defendant will make available a check in the amount of Three Hundred Forty Thousand dollars and no cents ($340,000) made payable "ARCH INSURANCE COMPANY". This amount represents a full and complete settlement of Plaintiffs claims for all damages alleged in the Action. Plaintiff will file the Request for Dismissal following Plaintiff's receipt and confirmation of the settlement check. Plaintiff agrees that this Agreement constitutes full and complete settlement of all claims made against Defendant in this Action. Plaintiff will not seek any further compensation for any other claimed damages, costs, or attorney's fees in connection with the matters encompassed in this Agreement. a. Plaintiff shall provide Defendant with a fully executed copy of this Agreement on or before July 16, 2025. b. Defendant shall deliver the settlement check, described above,to Plaintiff on or before July 31, 2025. The check shall be delivered to: Page 1 of 4