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12 This release and discharge shall apply to the past, present and future officers, <br />directors, stockholders, attorneys, agents, servants, representatives, employees, subsidiaries, <br />affiliates, partners, predecessors and successors in interest, and assigns and all other persons, <br />firms or corporations with whom any of the former have been, are now, or may hereafter be <br />affiliated of the City of Santa Ana, including but not limited to Officer Christopher Shynn. <br />1.3 This release, on the part of the Plaintiff, shall be a fully binding and complete <br />settlement among the Plaintiff and the Defendant, and their heirs, assigns and successors and <br />employees, including, but not limited to Officer Christopher Shynn, <br />1.4 The Plaintiff acknowledges and agrees that the release and discharge set forth <br />above is a general release. Plaintiff expressly waives and assumes the risk of any and all claims <br />for damages which exist as of this date, but of which the Plaintiff does not know or suspect to <br />exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if <br />known, would materially affect Plaintiff s decision to enter into this Settlement Agreement. The <br />Plaintiff further agrees that Plaintiff has accepted payment of the sums specified herein as a <br />complete compromise of matters involving disputed issues of law and fact. Plaintiff assumes the <br />risk that the facts or law may be other than Plaintiff believes. It is understood and agreed to by <br />the parties that this settlement is a compromise of a doubtful and disputed claim, and the <br />payments are not to be construed as an admission of liability on the part of the Defendant, by <br />whom liability is expressly denied. <br />2.0 PAYMENTS <br />In consideration of the release set forth above, the Defendant agrees to pay the payments <br />outlined in Sections 2.1 and 2.2 below: <br />2.1 Payments due at the time of settlement as follows: <br />$157,307.96 shall be in the form of a check made payable to "Guitar Henderson <br />& Carrazco LLP" <br />2.2 The Periodic Payments which constitutes damages (other than punitive damages) <br />received on account of Plaintiff s alleged personal physical injuries or sickness within the <br />meaning of section 104(x)(2) of the Internal Revenue Code of 1986, will be paid as follows: <br />Payee: Derek Canepa <br />$6,000.00 Payable quarterly, guaranteed for 28 payments only, commencing <br />7/6/2024 (age 18) through and including 4/6/2031; <br />$2,500.00 Payable monthly, guaranteed for 60 payments only, commencing 7/6/2031 <br />(age 25) through and including 6/6(2036 <br />$150,000.00 Guaranteed lump sum, payable on 7/6/2036 (age 30); <br />21 Page <br />