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APR/22/2013/MON 10:52 AM <br />FAX No, <br />A-2013-057 <br />SETTLEMENT AGREEMENT <br />AND RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release of All Claims (hereinafter "Agreement") <br />is made and entered into by and between CESAR LOPEZ (hereinafter referred to as <br />"Plaintiff'), and the CITY OF SANTA ANA, (hereinafter "Defendant"). <br />WITNESSETH: <br />WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of <br />the State of California, County of Orange, Central Justice Center District known as <br />CESAR LOPEZ v. CITY OF SANTA ANA, et al Case No. 30-2013-00635890 (the <br />"Action"). <br />WHEREAS, Plaintiff and the Defendant desire to settle fully and finally all <br />differences between them, including, but in no way limited to, those differences <br />described above. <br />NOW, THEREFORE, in consideration of the mutual covenants and promises <br />herein contained and other good and valuable consideration, receipt of which is hereby <br />acknowledged, and to avoid unnecessary litigation, it is hereby agreed by and between <br />the parties as follows: <br />FIRST: This Agreement and compliance with this Agreement shall not be <br />construed as an admission by the Defendant and of any liability whatsoever, or as an <br />admission by the Defendant of any violation of the rights of Plaintiff or any person, <br />violation of any order, law, statute, duty, or contract whatsoever against Plaintiff or any <br />person. The Defendant specifically disclaims any liability to Plaintiff or any other person <br />for any alleged violation of the rights of Plaintiff or any person, or for any alleged <br />violation of any order, law, statute, duty, or contract on the part of any employees, agents <br />of the City of Santa Ar-a. Likewise, this Agreement and compliance with this Agreement <br />shall not be construed as an admission by Plaintiff of any liability, misconduct, or <br />wrongdoing whatsoever. <br />SECOND: (a) Plaintiff will sign a Request for Dismissal of the Entire Action <br />with Prejudice form dismissing Case No. 30-2013-00635890 as to Defendants, City of <br />Santa Ana and Robert Hernandez Flores, in its entirety. <br />1