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F-13 14 SETUEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims (hereinafter "Agreement ") is made and entered into by and between LAURA SAUCEDA VARGAS, JOSEFINA VARGAS, OSCAR MORENO, A Minor by and through his Guardian Ad Litem, LAURA SAUCEDA VARGAS, JASMINE MORENO, A Minor by and through her Guardian Ad Litem, LAURA SAUCEDA VARGAS (hereinafter referred to as "Plaintiffs "), and the CITY OF SANTA ANA, (hereinafter "Defendant "). WITNESSETH: WHEREAS, Plaintiffs filed an action against Defendant in the Superior Court of the State of California, County of Orange, Central Justice Center District known as LAURA SAUCEDA VARGAS, et al. v. CITY OF SANTA ANA, or aL Case No. 30- 2014 - 00697500 -CU- PA-CJC (the "Action "). WHEREAS, Plaintiffs and the Defendant desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described above. NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and other good and valuable consideration, receipt of which is hereby acknowledged, and to avoid unnecessary litigation, it is hereby agreed by and between the parties as follows: FIRST: This Agreement and compliance with this Agreement shall not be construed as an admission by the Defendant and of any liability whatsoever, or as an admission by the Defendant of any violation of the rights of Plaintiffs or any person, violation of any order, law, statute, duty, or contract whatsoever against Plaintiffs or any person. The Defendant specifically disclaims any liability to Plaintiffs or any other person for any alleged violation of the rights of Plaintiffs or any person, or for any alleged violation of any order, law, statute, duty, or contract on the part of any employees, agents of the CITY OF SANTA ANA. Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiffs of any liability, misconduct, or wrongdoing whatsoever. SECOND: (a) Defendant will deliver to Plaintiffs'counsel, the following settlement checks in the amormts stated below for a total amount of TWELVE THOUSAND DOLLARS AND ZERO CENTS ($12,000,00) in full and complete settlement of all claims made against the City of Santa Ana in this litigation, The check is to be made out to "RKR LEGAL AND LAURA. SAUCEDA VARGAS AND JOS.EFNA VARGAS." This amount is in full and complete settlement for Plaintiffs' claims for all damages alleged in the above- referenced Complaint. The break-down of the settlement is as follow: