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(c) Plaintiff, NATALIA VELEDIAZ, and Defendants agree that the
<br />foregoing mutual dismissals constitute full and complete settlement of all claims made against all
<br />parties in this litigation. Plaintiff will not seek any further compensation for any other claimed.
<br />damage, costs, or attorney's fees in connection with the matters encompassed in this Agreement.
<br />(d) Plaintiff aelmowledges and agrees that the Defendants have made no
<br />representations regarding the tax consequences of any amounts received pursuant to this
<br />Agreement. Plaintiff agrees that she and she alone is liable for all taxes, if any, which are owed
<br />by her on any amount received hereunder including interest and penalties. Plaintiff will hold the
<br />Defendants harmless from any and all claims made by federal, state, or local taxing authorities or
<br />lien holders against Plaintiff on amounts owed by her.
<br />THIRD: Plaintiff represents that, with the exception of Case No. 30-2013-00662848
<br />and the government tort claim associated therewith, she has not filed any complaints, claims, or
<br />actions against Defendants including any of its officers, agents, directors, supervisors,
<br />employees, or representatives of CITY OF SANTA ANA with any state, federal, or local agency
<br />or court and that they will not do so at any time hereafter as it relates to this action and that if any
<br />agency or court assumes jurisdiction of any complaint, claim, or action against the Defendants on
<br />Plaintiff's behalf, Plaintiff will direct that agency or court to withdraw and dismiss with
<br />prejudice the matter.
<br />FOURTH: Plaintiff represents and warrants that no portion of any claim, right, demand,
<br />action or cause of action that she has or might have against Defendants or any portion of any
<br />recovery or settlement to which she may be entitled from Defendants, has been assigned or
<br />transferred to any person, entity or corporation in any manner, including by way of subrogation,
<br />transfer or operation of law. In the event that any claim, demand, suit or lien has or should have
<br />been made, is instituted against the Defendant because of any such purported assignment,
<br />subrogation, transfer or lien, Plaintiff agrees to indemnity and hold harmless the Defendant
<br />against any such claim, suit, demand, and to pay and satisfy any such claim, suit, demand or lien,
<br />including expense of investigation, attorney's fees and costs.
<br />FIFTH: The parties hereto hereby agree that all rights under Section 1542 of the Civil
<br />Code of the State of California are hereby waived. Civil Code Section 1542 provides as follows:
<br />"A general release does not extend to claims which the creditor does not
<br />know or suspect to exist in his or her favor at the time of executing the
<br />release, which if known by him or her must have materially affected his or
<br />her settlement with the debtor."
<br />SIXTH: Notwithstanding the provisions of Civil Code section 1542, each party hereby
<br />irrevocably and unconditionally releases and forever discharges each other party and each and all
<br />of its officers, agents, directors, supervisors, employees, representatives, and its successors and
<br />assigns and all persons acting by, through, under, or in concert with each other party from any
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