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SETTLEMENT AGREEMENT AND RELEASE
<br />THIS SETTLEMENT AGREEMENT AND RELEASE ("Agreement") is made and
<br />entered into this 3b TH day of March, 2022 ("Effective Date") between SBCW Consulting,
<br />Inc , a California corporation ("SBCW") and the City of Redlands, a California general law city
<br />("City"). SBCW and City are sometime individually referred to herein as a "Party" and, together,
<br />as the "Parties "
<br />RECITALS
<br />WHEREAS, on July 22, 2020, SBCW filed a complaint against City in California Supenor
<br />Court, San Bernardmo County, as Case No C1VDS2015309 titled S B C W Consultzng, Inc , a
<br />California corporation v City of Redlands ("Action"), and
<br />WHEREAS, having agreed to compromise, settle and discharge all claims, controversies,
<br />demands, and actions, or causes of action, which SBCW may have or claim to have agamst City,
<br />(including, without limitation, those claims made in the Action), the Parties to this Agreement now
<br />desire to memorialize that agreement in this fmal form,
<br />NOW, THEREFORE, IN CONSIDERATION of the promises, covenants and agreements
<br />herein contained, the Parties agree as follows.
<br />1 In exchange for the promises and releases contained herein, City agrees to pay the
<br />following in full settlement of any and all of SBCW's claims as set forth in the Action
<br />("Settlement Payment").
<br />Fifteen thousand dollars ($15,000), shall be paid by check made out to
<br />"S B C W Consulting, Inc " The Settlement Payment will be made
<br />within thirty (30) days of this Agreement being fully executed and
<br />City's receipt of SBCW's form W-9.
<br />2 Concurrently with the execution of this Agreement, SBCW shall execute such
<br />documents and perform such acts as are necessary to withdraw and/or dismiss with prejudice the
<br />Action and any other charges or complaints filed with any state or federal agency or court against
<br />City, as well as all agents, officers, directors, shareholders, employees, representatives, affiliated
<br />companies, sister companies, parent companies, contractors, and all persons actmg by, through,
<br />under, or in concert with any of them SBCW shall file and serve a dismissal, with prejudice, of
<br />the entirety of the Action within five (5) days of receiving the Settlement Payment
<br />3 In exchange for the promises contained herein, SBCW, and its successors and
<br />assigns, hereby irrevocably and unconditionally releases, acquits and forever discharges City, as
<br />well as all of City's current or former elected and appomted officials, officers, employees, and
<br />agents, and all persons actmg by, through, under or in concert with any of them, and each of their
<br />respective heirs, successors, and assigns (collectively, "Releasees"), or any of them, from any and
<br />all charges, complaints, claims, liabilities, obligations, promises, agreements, controversies,
<br />damages, actions, causes of action, suits, rights, demands, costs, losses, debts and expenses
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