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"RFD "), the Defendant will deliver to Plaintiffs counsel, a check in the amount of FIVE
<br />THOUSAND DOLLARS AND ZERO CENTS ($5,000.00) in full and complete
<br />settlement of all claims made against the City of Santa Ana in this litigation, The check is
<br />to be made out to "ANIKO RUSHAKOFF HOOVER, ATTORNEY AT LAW AND
<br />CONSUELO CASE." This amount is in full and complete settlement for Plaintiff's
<br />claims for all damages alleged in the above - referenced Complaint.
<br />(c) Plaintiff Consuelo Cases and Defendant City of Santa. Ana agree
<br />that the foregoing mutual dismissal constitute full and complete settlement of all claims
<br />made against all parties in this litigation. Plaintiff will not seek any further compensation
<br />for any other claimed damage, costs, or attorney's fees in connection with the matters
<br />encompassed in this Agreement.
<br />(d) Plaintiff acknowledges and agrees that the Defendant has made
<br />no representations to her regarding the tax consequences of any amounts received by her
<br />pursuant to this Agreement. Plaintiff agrees that she and she alone is liable for all taxes,
<br />if any, which are owed by her on any amount received hereunder including interest and
<br />penalties. Plaintiff will hold the Defendant harmless from any and all claims made by
<br />federal, state, or local taxing authorities or lien holders against Plaintiff on amounts owed
<br />by her.
<br />THIRD: Plaintiff represent that, with the exception of Case No. 30 -2013-
<br />00628729 she has not filed any complaints, claims, or actions against Defendant
<br />including any of its officers, agents, directors, supervisors, employees, or representatives
<br />of City of Santa Ana with any state, federal, or local agency or court and that lie will not
<br />do so at any time hereafter as it relates to this action and that if any agency or court
<br />assumes jurisdiction of any complaint, claim, or action against the Defendant 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,
<br />right, demand, action or cause of action that he has or might have against Defendant and
<br />any officers, agents, directors, supervisors, employees, or representatives of the City of
<br />Santa Ana or any portion of any recovery or settlement to which he may be entitled from
<br />Defendant, has been assigned or transferred to any person, entity or corporation in any
<br />manner, including by way of subrogation, transfer or operation of law, In the event that
<br />any claim, demand, suit or lien has or should have been made were instituted against the
<br />Defendant including the officers, agents, directors, supervisors, employees, or
<br />representatives because of any such purported assignment, subrogation, transfer or lien,
<br />Plaintiff agrees to indemnify and hold harmless the Defendant and the officers, agents,
<br />
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