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A- 2014 -278 <br />4' <br />r4 <br />SETTLEMENT AGREEMENT <br />G AND MUTUAL RELEASE OF CLAIMS <br />This Settlement Agreement and Mutual Release of Claims (hereinafter referred to as the <br />1- "AGREEMENT ") is entered into by and between ARNIE PIKE (hereinafter referred to as <br />"PIKE "), and the CITY OF SANTA ANA (hereinafter referred to as "CITY "). PIKE and the <br />k�, CITY may individually be referred to as a PARTY or collectively as the "PARTIES ". <br />This AGREEMENT acts exclusively to settle PIKE'S claims for removal of the <br />architectural barriers to disabled access he alleges exist at the Bowers Museum, located at 2002 <br />N. Main Street, Santa Ana, California 92706 (the "PREMISES "). The PARTIES agree that the <br />terms of this AGREEMENT will satisfy all of PME'S claims regarding the removal of the <br />architectural barriers to disabled access at the PREMISES, In order to avoid the costs, expense, <br />and uncertainty of protracted litigation, the PARTIES hereby enter into this Agreement as set <br />forth below. <br />RECITALS <br />This AGREEMENT is based on the following facts: <br />A. On or around March 4, 2013, PIKE addressed a letter to the CHARLES W. <br />BOWERS MUSEUM CORPORATION (hereinafter referred to as "BOWERS ") and the CITY <br />in which he notified BOWERS and the CITY of certain alleged barriers to disabled access at the <br />PREMISES, including, but not limited to, inaccessible parking for persons with disabilities and <br />inaccessible paths of travel to and throughout the PREMISES. <br />B. Without any admission of liability or any admission that the PREMISES do not <br />meet accessibility standards and codes, the CITY has agreed to undertake remedial work at the <br />PREMISES to improve and ensure accessibility for persons with mobility disabilities. <br />Page I <br />