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(i) <br />A payment of fifty thousand dollars and zero cents ($50,000 00) to <br />A Cisneros, Trustee of the Bankruptcy Estate of Gina Ruan and <br />Santos Ruan by SOFTSCAPES and FPA6, <br />(11) A payment of fifteen thousand dollars and zero cents ($15,000) to <br />A Cisneros, Trustee of the Bankruptcy Estate of Gina Ruan and <br />Santos Ruan by CITY, <br />(b) The above -referenced consideration of SOFTSCAPES,FPA6, and CITY <br />shall be hereinafter referred to as the "SETTLEMENT PAYMENTS " <br />(1) <br />The SETTLEMENT PAYMENTS shall be made payable as <br />follows <br />A Cisneros, Trustee of the Bankruptcy Estate of Gina Ruan and <br />Santos Ruan <br />(n) The SETTLEMENT PAYMENTS shall be mailed to <br />Malcolm ♦ Cisneros, A Law Corporation, Attention A Cisneros, <br />3403 10th Street, Suite 714, Riverside, CA 92501 <br />(c) PLAINTIFF shall provide his original signature to counsel for <br />SOFTSCAPES,FPA6 and CITY, who will provide a fully -executed copy of <br />this AGREEMENT to all counsel Facsimile or electronic signatures are <br />also acceptable and shall have the same force and effect as an original <br />3 Subject to Approval of the United States Bankruptcy Court The Parties agree that <br />this Settlement Agreement is subject to the approval of the Bankruptcy Court in the Bankruptcy <br />Case If this Agreement is not approved by the Bankruptcy Court, it will be of no force or effect <br />4 Dismissal PLAINTIFF agrees to dismiss the ACTION with prejudice within <br />fourteen (14) days of PLAINTIFF'S receipt of the SETTLEMENT PAYMENTS and entry of a <br />Bankruptcy Court order approving this AGREEMENT by filing a Request for Dismissal with <br />Prejudice in the ACTION <br />PLAINTIFF further agrees and represents that, upon execution of this AGREEMENT and <br />dismissal of the ACTION with prejudice, PLAINTIFF will not file any action or proceeding <br />regarding the SUBJECT INCIDENT or in relation, in any way, to the ACTION and that <br />PLAINTIFF'S claims against SOFTSCAPES, FPA6, and CITY will be fully satisfied and resolved <br />through this AGREEMENT <br />SOFTSCAPES, FPA6, and the CITY agree to dismiss all Cross -Claims against one another <br />with prejudice within fourteen (14) days of entry of a Bankruptcy Court order approving this <br />AGREEMENT by filing Requests for Dismissal with Prejudice in the ACTION <br />5 Release For and in consideration of the terms and conditions outlined herein, <br />SETTLING PARTIES do hereby fully, forever, finally, generally, and completely release, relieve, <br />3 <br />