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(a) The City of Santa Ana's Community Preservation inspectors <br />inspected the property located at 1820 E. Garry Avenue, Unit 2C4, in the City of Santa <br />Ana and determined that Defendant has ceased operation at that property, <br />(b) The Parties hereby stipulate to have Judgment entered in the civil <br />action for Plaintiff; the People of the State of California, and Plaintiff and Real Party in <br />Interest, the City of Santa Ana, and against Defendant and Haat Defendant will be <br />permanently enjoined from leasing to or operating a medical marijuana <br />dispensary/collective/cooperative anywhere within the City of Santa Ana until such time <br />as it is allowed pursuant to local or state law or permit. <br />(c) Each side to bear their own costs and attorney fees. Pursuant to Code of <br />Civil Procedure 664.6, the patties will request that the Court retain jurisdiction over the <br />parties to enforce the terms of this settlement until performance in fall of the terms of the <br />settlement, <br />(d) In the event that the Court does not enter Judgment as requested, this <br />settlement agreement in its entirety will be null and void and the pending cases will revert <br />back to its prior state with all affirmative allegations and defenses retained by all parties. <br />THIRD: Plaintiff and Defendant, Tam Ton Nguyen agreed to a civil compromise <br />in the amount of $10,000 that was paid to the "City of Santa Ana" in settlement of the <br />above Criminal Action, receipt of which is hereby acknowledged. <br />FOURTH- Plaintiffs represent that, with the exception of the Civil Action and the <br />Criminal Action referenced above, they have not filed any other complaints, claims, or <br />actions against Defendant with any state, federal or local agency or court <br />FIFTH- The Parties hereto herby agree that all rights under Section 1542 of <br />the Civil Code of the State of California are hereby waived. Civil Code Section 1542 <br />provides as follows: <br />"A general release does not extend to claims which the creditor does not know <br />or suspect to exist in his or her favor at the time of executing the release, which if <br />known by him or her must have materially affected his or her settlement with the <br />debtor." <br />SIXTH: The parties represent that they have reviewed all aspects of this <br />Agreement, that the Agreement has been carefully read and fully explained to them and <br />that they understand all the provisions of this Agrecineut, that they understand that in <br />agreeing to this document, they are releasing each other frorn any and all claims they may <br />have against each other, that they voluntarily agree to all the terms set forth in this <br />Agreement, that they knowingly and willingly intend to be legally bound by the same, <br />