QUINTANILLA, ANTONIO & MONTOYA, ISABEL WARAHI

Home Browse Search

527 A-2016-223 SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made and entered into by and between ANTONIO QUINTANILLA, and ISABEL SARAHI MONTOYA (collectively hereinafter referred to as "Plaintiffs"), and CITY OF SANTA ANA and RAUL MAYORGA (collectively referred to hereafter as "Defendants"). WITNESSETH: WHEREAS, Plaintiffs filed an action against Defendants in the Superior Court of the State of California, County of Orange, Central Justice Center District known as ANTONIO OUINTANILLA. SANDRA JEANNETTE OUINTANILLA and ISABEL SARAHI MONTOYA v. THE CITY OF SANTA ANA, et al., Case No. 30-2015-00803957 (the "Action"). WHEREAS, Plaintiffs and Defendants desire to settle fully and finally all differences between them, including, but in no way limited to, those differences described above. NOW, THEREFORE, in consideration of the mutual covenants and promises herein contained and other good and valuable consideration, receipt of which is hereby acknowledged, and to avoid unnecessary litigation, it is hereby agreed by and between the parties as follows: FIRST: This Agreement and compliance with this Agreement shall not be construed as an admission by Defendants of any liability whatsoever, or as an admission by Defendants of any violation of the rights of Plaintiffs or any person, violation of any order, law, statute, duty, or contract whatsoever against Plaintiffs or any person. Defendants specifically disclaim any liability to Plaintiffs or any other person for any alleged violation of the rights of Plaintiffs or any person, or for any alleged violation of any order, law, statute, duty, or contract on the part of any employees or agents of the CITY OF SANTA ANA. Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiffs of any liability, misconduct, or wrongdoing whatsoever. SECOND: (a) Plaintiffs, ANTONIO QUINTANILLA and ISABEL SARAHI MONTOYA, will each sign and file a Request for Dismissal with Prejudice form dismissing Case No. 30-2015-00803957 as to Defendants, CITY OF SANTA ANA and PAUL MAYORGA, . (b) At the time Plaintiffs deliver to counsel for Defendants a fully signed original of this Agreement and an executed copy of the Request for Dismissal as to each of those Plaintiffs' claims, Defendants will deliver to those Plaintiffs, two checks made payable as follows: (1) ANTONIO QUINTANILLA AND TREYZON & ASSOCIATES, LLP in the amount of $55,000.00, and (2) ISABEL SARAHI MONTOYA AND TREYZON & ASSOCIATES, LLP in the amount of $7,000.00. These amounts are in full and complete settlement for those Plaintiffs' claims for all damages alleged in the above -referenced Complaint.