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SETTLEMENT AGREEMENT & GENERAL RELEASE
<br />This Settlement Agreement and General Release (the "Agreement") is entered into this 1 st
<br />day of March, 2022, by and between Steve Unland, an individual ("Unland") and Defendant City
<br />of Redlands ("City") Unland and City are sometimes individually referred to herein as a Party
<br />and, together, as the "Parties "
<br />RECITALS
<br />WHEREAS, on or around July 9, 2018, Unland commenced employment with City
<br />("Employment"), and
<br />WHEREAS, on or about January 18, 2019, Unland's Employment with City ended
<br />("Employment End Date"), and
<br />WHEREAS, subsequently, Unland asserted that City's termination of Unland's
<br />Employment was unlawful (the "Claims"), and
<br />WHEREAS, on or about September 20, 2019, Unland filed a Complaint with the Superior
<br />Court of the County of San Bernardino against City (the "Lawsuit"), and
<br />WHEREAS, on or about February 11, 2020, City filed an Answer to Unland's Complaint.
<br />Therein, City denied generally and specifically each and every allegation of the Complaint, denied
<br />it is liable to Unland in any amount, and denied that Unland has sustained damages by reason of
<br />any act or omission of City; and
<br />WHEREAS, the Parties, on behalf of themselves and their current and former employees,
<br />agents, officers, City's council members, representatives, assigns, successors -in -interest, heirs,
<br />counsels, and insurers now desire to resolve and settle all claims, counter -claims, and dispute
<br />arising from or involving the Employment, Claims, and/or Lawsuit; and
<br />WHEREAS, the Parties agree and mutually acknowledge that this Agreement is for
<br />settlement purposes only City has denied and continues to deny any wrongdoing in connection
<br />with the Employment, Claims, and/or Lawsuit. Neither this Agreement nor any action taken
<br />pursuant to this Agreement shall constitute an admission of any wrongdoing, fault, violation of
<br />law, or liability of any kind on the part of the Parties, or any admission by and of the Parties of any
<br />claim or allegations made in any claim against such party This Agreement is entered into, in
<br />substantial part, to avoid the fees and expenses associated with any potential litigation over the
<br />Employment, Claims, and/or Lawsuit. The Parties agree that this Agreement shall be inadmissible
<br />as evidence of liability or damages in any forum or proceeding,
<br />AGREEMENT
<br />1 The Parties acknowledge that the recitals stated above are true and correct and
<br />incorporate by reference those recitals into this Agreement.
<br />2 In consideration of this Agreement and the promises set forth herein, City shall pay
<br />Unland the total sum of Twenty Seven Thousand Nine Hundred Dollars ($27,900 00) ("Settlement
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<br />17942.00126\34859171.1
<br />Doc ID e6b7fc93fc57660ffd44bdc34c9bc52e5faea9a6
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