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CONSUELO CASE
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Last modified
6/29/2016 1:09:09 PM
Creation date
5/13/2016 4:48:03 PM
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Contracts
Company Name
CONSUELO CASE
Contract #
A-2014-122
Agency
City Attorney's Office
Council Approval Date
6/3/2014
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SETTLEMENT AGREEMENT <br />AND RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release of Alt Claims (hereinafter "Agreement ") <br />is made and entered into by and between CONSUELO CASE (hereinafter referred to as <br />"Plaintiff'), and the CITY OF SANTA ANA, (hereinafter "Defendant "), <br />WITN]ESSlETH[: <br />WHEREAS, Plaintiff' filed an action against Defendant in the Superior Court of <br />the State of California, County of Orange, Central Justice Center District known as <br />CONSUELO CASE v. CITY OF SANTA ANA et al. Case No, 30- 2013-00628729 (the <br />"Action"), <br />WHEREAS, Plaintiff and the 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 />actmowledged, 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 the Defendant and of any liability whatsoever, or as an <br />admission by the Defendant of any violation of the rights of Plaintiff or any person, <br />violation of any order, law, statute, duty, or contract whatsoever against Plaintiff or any <br />person, The Defendant specifically disclaims any liability to Plaintiff or any other person <br />for any alleged violation of the rights of Plaintiff or any person, or for any alleged <br />violation of any order, law, statute, duty, or contract on the part of any employees, agents <br />of the City of Santa Ana, Likewise, this Agreement and compliance with this Agreement <br />shall not be construed as an admission by Plaintiff of any liability, misconduct, or <br />wrongdoing whatsoever. <br />SECOND: (a) Plaintiff will sign a Request for Dismissal of the Entire Action. <br />with Prejudice form dismissing Case No, 30- 2013 - 00628729 as to Defendant, City of <br />Santa Ana, in its entirety. <br />(b) At the time Plaintiff' delivers to counsel for the Defendant a fully <br />signed original of this Agreement, and an executed Request for Dismissal form (the <br />1 <br />
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