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LOPEZ, CESAR
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LOPEZ, CESAR
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Last modified
9/30/2013 12:30:41 PM
Creation date
9/30/2013 9:34:09 AM
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Contracts
Company Name
LOPEZ, CESAR
Contract #
A-2013-057
Agency
City Attorney's Office
Council Approval Date
4/15/2013
Destruction Year
0
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APR/22/2013/MON 10:52 AM FAX No, P,004/008 <br />(b) At the time Plaintiff delivers to counsel for the Defendant a fully <br />signed original of this Agreement, and an executed Request for Dismissal form (the <br />"RFD"), the Defendant will deliver to Plaintiffs counsel, a check in the amount of TEN <br />THOUSAND DOLLARS AND ZERO CENTS ($10,000.00) in full and complete <br />settlement of all claims made against the City of Santa Ana in this litigation. The check is <br />to be made out to "WOODS & XOO, PC AND CESAR LOPEZ." This amount is in full <br />and complete settlement for Plaintiff's claims for all damages alleged in the above- <br />referenced Complaint. <br />(b) Plaintiff Cesar Lopez and Defendant City of Santa Ana agree that <br />the foregoing mutual dismissal constitute full and complete settlement of all claims made <br />against all parties in this litigation. Plaintiff will not seek any further compensation for <br />any other claimed damage, costs, or attorney's fees in connection with the matters <br />encompassed in this Agreement. <br />(c) Plaintiff acknowledges and agrees that the Defendant has made <br />no representations to him regarding the tax consequences of any amounts received by <br />him pursuant to this Agreement. Plaintiff agrees that he and he alone is liable for all <br />taxes, if any, which are owed by her on any amount received hereunder including interest <br />and penalties. Plaintiff will hold the Defendant harmless from any and all claims made <br />by federal, state, or local taxing authorities or lien holders against Plaintiff on amounts <br />owed by him. <br />THIRD: Plaintiff represent that, with the exception of Case No. 30-2013- <br />00635890 he has not filled any complaints, claims, or actions against Defendant including <br />any of its officers, agents, directors, supervisors, employees, or representatives of City of <br />Santa Ana with any state, federal, or local agency or court and that he will not do so at <br />any time hereafter as it relates to this action and that if any agency or court assumes <br />jurisdiction of any complaint, claim or action against the Defendant on Plaintiff's behalf, <br />Plaintiff will direct that agency or court to withdraw and dismiss with prejudice the <br />matter. <br />FOUR'T'H: Plaintiff represents and warrants that no portion of any claim, <br />right, demand, action or cause of action that he has or might have against Defendant and <br />any officers, agents, directors, supervisors, employees, or representatives of the City of <br />Santa Ana or any portion of any recovery or settlement to which he may be entitled from <br />Defendant, has been assigned or transferred to any person, entity or corporation in any <br />manner, including by way of subrogation, transfer or operation of law. In the event that <br />any claim, demand, suit or lien has or should have been made were instituted against the <br />2
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