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A-2016-293 <br />SETTLEMENT AGREEMENT <br />AND RELEASE OF ALL CLAIMS <br />This Settlement Agreement and Release of All Claims (hereinafter "Agreement") is made <br />and entered into by and between SANDRA JEANNETTE QUINTANILLA (hereinafter <br />"Plaintiff"), and CITY OF SANTA ANA and RAUL MAYORGA (collectively referred to <br />hereafter "Defendants"). <br />WITNESSETH: <br />WHEREAS, three Plaintiffs filed an action against Defendants in the Superior Court of <br />the State of California, County of Orange, Central Justice Center District known as ANTONIO <br />OUINTANILLA SANDRA JEANNETI'E QUINTANILLA and ISABEL SARAHI MONTOYA <br />v. THE CITY OF SANTA ANA, et al„ Case No. 30 -2015 -00803957 -CU -NP -CIC (the "Action"). <br />WHEREAS, Plaintiff, Sandra Jeannette Quintanilla, and Defendants (collectively referred <br />to hereafter as "Parties") desire to settle fully aid finally all differences between them, including, <br />but in no way limited to, those differences described above. <br />NOW, THEREFORE, in consideration of the mutual covenants and promises herein <br />contained and other good and valuable consideration, receipt of which is hereby acknowledged, <br />and to avoid unnecessary litigation, it is hereby agreed by and between the parties as follows: <br />FIRST: This Agreement and compliance with this Agreement shall not be construed as <br />an admission by Defendants and of any liability whatsoever, or as an admission by Defendants of <br />any violation of the rights of Plaintiff or any person, violation of any order, law, statute, duty, or <br />contract whatsoever against Plaintiff or any person. Defendants specifically disclaim any liability <br />to Plaintiff or any other person for any alleged violation of the rights of Plaintiff or any person, or <br />for any alleged violation of any order, law, statute, duty, or contract on the part of any employees, <br />agents of Defendants. Likewise, this Agreement and compliance with this Agreement shall not be <br />construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever, <br />SECOND: (a) Each party will exchange a fully signed executed copy or original of this <br />Agreement. Defendants cannot proceed with processing payment without a fully executed copy <br />of the Agreement from Plaintiff. <br />(b) Following receipt of, or in exchange for, an executed copy of a Request <br />for Dismissal form from Plaintiff dismissing this Action with prejudice, Defendants will mance <br />available a check in the amount of One Hundred and Five Thousand Dollars ($105,000.00) in full <br />and complete settlement of all claims made against the City of Santa Ana and Raul Mayorga in <br />this Action. The check will be made payable to "SANDRA JEANNETTE QUINTANILLA AND <br />TREYZON & ASSOCIATES, LLP". This amount is in full and complete settlement for Plaintiffs <br />claims for all damages alleged in the Action. Defendants will file the Request for Dismissal. <br />Page 1 of 4 <br />