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r (c) Plaintiff, PATRICIA KOSTER, and Defendant, CITY OF SANTA ANA, agree that the foregoing mutual dismissals constitute full and complete settlement of all claims made against all parties in this litigation. Plaintiff will not seek any further compensation for any other claimed damage, costs, or attorney's fees in connection with the matters encompassed in this Agreement. (d) Plaintiff acknowledges and agrees that the Defendant had made no representations regarding the tax consequences of any amounts received pursuant to this Agreement. Plaintiff agrees that she and she alone is liable for all taxes, if any, which are owed by her on any amount received hereunder including interest and penalties. Plaintiff will hold the Defendant harmless from any and all claims made by federal, state, or local taxing authorities or lien holders against Plaintiff on amounts owed by her. THIRD: Plaintiff represents that, with the exception of Case No. 30-2011-00518423 and the government tort claim associated therewith, she has not filed any complaints, claims, or actions against Defendant including any of its officers, agents, directors, supervisors, employees, or representatives of CITY OF SANTA ANA with any state, federal, or local agency or court and that they will not do so at any time hereafter as it relates to this action and that if any agency or court assumes jurisdiction of any complaint, claim, or action against the Defendant on Plaintiff's behalf, Plaintiff will direct that agency or court to withdraw and dismiss with prejudice the matter. FOURTH: The parties hereto hereby agree that all rights under Section 1542 of the Civil Code of the State of California are hereby waived. Civil Code Section 1542 provides as follows: "A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which if (mown by him must have materially affected his settlement with the debtor." FIFTH: Notwithstanding the provisions of Civil Code section 1542, each party hereby irrevocably and unconditionally releases and forever discharges each other party and each and all of its officers, agents, directors, supervisors, employees, representatives, and its successors and assigns and all persons acting by, through, under, or in concert with each other party from any and all charges, complaints, claims, and liabilities of any kind or nature whatsoever, known or unknown, suspected or unsuspected (hereinafter referred to as "claim" or "claims") which each releasing party at any time heretofore had or claimed to have or which each releasing party at any time hereafter may have or claim to have, incidental to the incident(s) which form the basis of this lawsuit.