CARMAGO,TONY-2017 - Laserfiche WebLink

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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 "CONY CAMARGO (hereinafter as "Plaintiff"), and CITY OF SANTA ANA (hereafter as "Defendant"), WITNESSETH: WHEREAS, Plaintiff filed an action against Defendant in the Superior Court of the State of California, County of Orange, Central Justice Center District known as TONY CAMARGO v. CITY OF SANTA ANA, Case No, 30-2016-00872027-CU-PO-CJC (the "Action"), WHEREAS, Plaintiff and Defendant (collectively hereafter "parties"), 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 the Defendant and of any liability whatsoever, or as an admission by the Defendant of any violation of the rights of Plaintiff or any person, violation of any order, haw, statate, duty, or contract whatsoever against Plaintiff or any person, Defendant specifically disclaims any liability to Plaintiff or any other person for airy alleged violation of the rights of Plaintiff or any person, or for any alleged violation of any order, 'law, statute, ditty, or contract on the part of any employees, agents of Defendant, Likewise, this Agreement and compliance with this Agreement shall not be construed as an admission by Plaintiff of any liability, misconduct, or wrongdoing whatsoever. SECOND: (a) Each party will exchange a fully signed executed copy or original of this Agreement. Defendant cannot proceed with processing payment without a fully executed copy of the Agreement from Plaintiff. (b) The City agrees to pay the sum of Two Hundred and Twenty Five Thousand Dollars ($225,000.00) infull and complete settlement of all claims made against the Defendant in this action in exchange for, an executed copy of the Request for Dismissal with prejudice of the foregoing Action. Listed below is the breakdown of the distribution of the settlement funds as follows: (c) A check payable to "TONY CAMARGO AND HIS ATTORNEY OF RECORD, THE LAW OFFICES OF Ah MOTLAGH" in the amount of One Hundred acrd Nineteen Thousand, Two Hundred and F'i'fty Dollars and Forty -Three cents ($119,250.43). Page I of 4