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<br /> 01 TiY C1.Eltili
<br /> DATE: NOV 0 3 2025
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<br /> Suzanne.St.Ottt4 f SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS
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<br /> This Settlement Agreement and Release of All Claims("Agreement") is made and entered into by
<br /> and between ED DANOFF("Plaintiff") and the CITY OF SANTA ANA, SERGIO VERINO,
<br /> SONIA R. CARVALHO, KYLE C.NELLESEN, VALERIE AMEZCUA, THAI VIET PHAN,
<br /> JESSIE LOPEZ, JOHNATHAN RYAN HERNANDEZ,BENJAMIN VAZQUEZ, PHIL
<br /> BACERRA, DAVID PENZLOZA, SHERI L. FREIDENRICH and SLS PROPERTY SOLUTIONS,
<br /> INC., (collectively,"Defendants").
<br /> WITNESSETH:
<br /> WHEREAS, Plaintiff hied an action against Defendants in the Superior Court of the State
<br /> California,County of Orange, Central Justice Center known as EDWARD R.DANOFF JR. v. CITY
<br /> OF SANTA AN&et al.Case No. 30-2023-01342283-CU-CR-CJC(the"Action").
<br /> WHEREAS, Plaintiff and Defendants(collectively,the"Parties"),desire to settle fully and finally
<br /> all differences between them,including, but in no way limited to,those differences described above.
<br /> WHEREAS,the Court granted Defendants' Anti-SLAPP Motion in favor of Defendants represented
<br /> by the City of Santa Ana and against Plaintiff on February 14,2025.
<br /> WHEREAS,Defendants filed a Motion for Statutory Attorney's Fees that is set to be heard on
<br /> September 15,2025, as a result of prevailing on the Anti-SLAPP Motion.
<br /> WHEREAS,Plaintiff filed his Notice of Appeal on April 7,2025.
<br /> WHEREAS, Defendant SLS Property Solutions,Inc. filed a Demurrer that is to be heard on
<br /> November 10, 2025, and an Anti-SLAPP Motion that is to be heard on September 29, 2025.
<br /> NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained
<br /> and other good and valuable consideration,receipt of which is hereby acknowledged, and to avoid
<br /> unnecessary litigation, it is hereby agreed by and between the Parties as follows:
<br /> I. This Agreement and compliance with this Agreement shall not be construed as an admission
<br /> by Defendants of any liability whatsoever, or as an admission by Defendants of any violation of the
<br /> rights of Plaintiff or any person, violation of any order, law,statute,duty, or contract whatsoever
<br /> against Plaintiff or any person. Defendants specifically disclaim any liability to Plaintiff or each
<br /> other or any other person for any alleged violation of the rights of Plaintiff or any person,or for any
<br /> alleged violation of any order, law, statute, duty,or contract on the part of any employees or agents
<br /> of Defendants. Likewise, this Agreement and compliance with this Agreement shall not be
<br /> construed as an admission by Plaintiff of any liability,misconduct, or wrongdoing whatsoever.
<br /> Likewise this Agreement and compliance with this Agreement shall not be construed as an
<br /> admission by Plaintiff that Defendants did not violate the rights of Plaintiff.
<br /> 2. Each party will exchange a fully signed executed copy, or original,of this Agreement.
<br /> 3. Plaintiff hereby agrees to dismiss the entire action against all Defendants with prejudice and
<br /> further agrees to dismiss the pending Appeal Case No. G065380 and will forever relinquish any and
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