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N-2017-186 18 2017 Cr. C AtD a� �M&(qjouu 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 CITY OF SANTA ANA (hereinafter as "Plaintiff'), and JOSEPH SA:ADI. (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 CITY OF SANTA ANA .v_ JEPH SAADI Case No. 30-2016-00836447-CU-MC-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, law, statute, duty, or contract whatsoever against Plaintiff or any person. Defendant specifically disclaims any liability to Plaintiff or any other person for any alleged violation of the rights of Plaintiffor any person, or for any alleged violation of any order, law, statute, duty, 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. ?„tCNiiNDD: (a) The parties will exchange a fully signed executed copy or original of this Agreement. (b) Following the fully executed settlement agreement, Defendant Joseph Saadi will issue a check in the amount of Fifteen Thousand Dollars ($15,000.00) in full and complete settlement of all claims made against the Defendant, Joseph Saadi in this litigation. The check will be made payable to "CITY OF SANTA ANA". This amount is in full and complete settlement for Plaintiffs claims for all damages alleged in the above -referenced Complaint. Plairitiff City of Santa Ana will file the Request for Dismissal. (c) Parties agree that this Agreement and the payment specified in subsection (b) above, constitutes full and complete settlement and compromise of all claims made against the Defendant in the Action. Plaintiff specifically agrees that by accepting the foregoing Page 1 of 4