Laserfiche WebLink
2015 N-2415-034 <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 the CITY OF SANTA ANA in its individual <br />capacity and in its representative capacity for the PEOPLE OF THE STATE OF <br />CALIFORNIA (hereinafter referred to as "Plaintiffs"), and TAM NGUYEN (hereinafter <br />"Defendant"). <br />"WITNESSETH: <br />WHEREAS, Plaintiff, People of the State of California filed a civil action against <br />Defendant, Tam Nguyen, in the Superior Court of the State of California, County of <br />Orange, Central Justice Center District known as PEOPLE OF THE STATE OF <br />CALIFORNIAICITY OF SANTA ANA v. TAM NGUYEN et al. Case No. 30-2013- <br />00694333-CU-OR-CJC (the "Civil Action"). Plaintiff, People of the State of California, <br />also filed a criminal action against Defendant in the Superior Court of the State of <br />California, County of Orange, Central Justice Center District known as PEOPLE OF <br />THE STATE OF CALIFORNIA v. TAM TON NGUYEN No. 12CM09543 (the <br />"Criminal Action.") <br />WHEREAS, Defendant denies such allegations, and <br />WHEREAS, Plaintiffs and 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 Defendant of any liability whatsoever. Defendant <br />specifically disclaims any liability to Plaintiffs and/or any alleged violation of any order, <br />law, statute, duty or contract on the part of the Defendant. Likewise, this Agreement and <br />compliance with this Agreement shall not be construed as an admission by Defendant of <br />any liability, misconduct, or wrongdoing whatsoever. <br />SECOND: The Parties hereby agree to the following terms: <br />