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Vinesign Document ID: 300602D2-1 DF4-468F-A3C4-8F547B6627DE N-2026_0% <br /> INSURANCE NOT REQUIRED Return FULLY EXECUTED <br /> VgORK MAY PROCEED Copy to City Clerk, M-30 <br /> CITY CLERK <br /> DATE:MAR 0 5 ?P` SETTLEMENT AGREEMENT <br /> ` 't <br /> ppi r-y AND GENERAL RELEASE <br /> v�Fer nagdE2 j <br />'ton.4VIC)iT6rKevgt(01) <br /> This Settlement Agreement and General Release ("Agreement") by and between Madeline <br /> Reid (referred herein as "Plaintiff'), the City of Santa Ana, and Santa Ana School District <br /> (collectively "Defendants") effective as of the date it is executed the Parties ("Effective Date"). <br /> Plaintiff and Defendants may be referred to herein individually as a "Party" and collectively as "the <br /> Parties." <br /> RECITALS <br /> A. Plaintiff filed a Complaint on or about March 17, 2025, Case Number 30-2025- <br /> 01467720-CU-PO-NJC ("Action"). The Action related to claims of premises liability, general <br /> negligence, and dangerous condition of public property. The allegations contained in the Action are <br /> incorporated by reference in these Recitals. <br /> B. Plaintiff and Defendants are desirous of adjusting and finally settling any and all <br /> existing or potential claims, contentions and disputes between each other, their agents, attorneys, <br /> servants, employees and assigns, as more fully set forth below, for any event or occurrence in any <br /> way related to the matters set forth in the Action, such that a full, final and complete resolution of <br /> any claims between the Parties may be effected. <br /> C. All Parties desire to be released from any present and potential liability or obligation <br /> and desire to compromise all disputes and claims arising between them in consideration of the <br /> benefit to be received from avoidance of any further expenses and costs of litigation and agree to <br /> enter into this Agreement. <br /> D. Although each Party disputes any claims the other Party may allege for relief, <br /> damage, fees, costs, or expenses arising out of the incident alleged in the Action, and specifically <br /> denies any liability therefor, the Parties desire to avoid the risks and expenses attendant to litigation <br /> and to reach a compromise and settlement of all matters, claims, and causes of action on the terms <br /> described herein. As set forth below, the Parties wish to forever release, waive, and discharge all <br /> claims whatsoever they have against each other resulting from, or in connection with, the foregoing <br /> allegations, in exchange for the consideration set forth below as currently constituted as of the date <br /> of execution of this Agreement, and with no modifications now or in the future. <br /> TERMS OF AGREEMENT <br /> NOW, THEREFORE, for and in consideration of the foregoing Recitals, and of other good <br /> and valuable consideration, the sufficiency of which is hereby acknowledged, the Parties to this <br /> Agreement agree as follows; <br /> I. Payment, Defendants will pay Plaintiff the total sum of Thirty-Five Thousand <br /> Dollars and Zero Cents ($35,000.00)to resolve this matter ("Settlement Payment"). Such sum shall <br /> be in a settlement check or multiple settlement checks made payable to MVP Trial Lawyers Client <br /> Trust Account FBO Madeline Reid. Santa Ana Unified School District shall pay twenty thousand <br /> and zero cents towards the Settlement Payment, and the City of Santa Ana shall pay fifteen thousand <br /> and zero cents towards the Settlement Payment. <br /> 2. Disbursement. Defendants shall issue the Settlement Payment no later than thirty <br /> (30) days following the effective date of this Agreement. <br /> I <br /> The signed document can be validated at httpsa/app.vinesign.com/Verify <br />