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.AGREEMENT OF SETTLEMENT AND
<br />GENERAL. RELEASE
<br />I. P,:I R.T'lL',S': 'Tice parties to this Agrecnient.ot' Settlement and Clene Cal Release ("Agreement")
<br />are Pa.ntela Nelson ("Plaintiff"),, and ('ity of Redlands ("Defendant")
<br />2, RECITALS: This Agreement is nittdt with reference to the following facts:•
<br />2.1 Certain disputes and controversies have arisen between the parties hereto.
<br />2,2 Such diSptites and controversies include, but are not limited to, the claims, demands
<br />and case or causes o1'aution set. forth by the parties hereto in a civil action pending in the
<br />San Bernardino C.oun.ty.Superior:Caurf and entitled Pamela Nelson v City ofRedlands, et
<br />al, Case. No, Cl•VDS 2104053.
<br />2,3 It is the intention Of the parties hereto. to settle and dispose Or, fully and completely,
<br />• atiy and all c:1unis, demands and cause car of grses of action e\ibtiing as Of the effe etive date
<br />of this agreement and arising out of:, connected with, or incidental to the dealings between
<br />part.leb.hcreto to the ei'feetive date he reof°`includitig, without liniitati.on oa the generality
<br />of the foregoing, any and all claims, demands and pause: of causes of action reflected in
<br />the civil action referenced in Paragraph 2.2 tit'Gve.
<br />3..DaAS;11851A11:: Concurrently Nvi.th.the. exccution of this Agreements, Plaintiffsshalldismiss, with
<br />prejudice, the civil action ref+wrenced in Paragraph 2,2 above, in exchange rear the promises,
<br />Covenants, conditions aid p4ayinents..set: forth in Paragraph Pour,
<br />4, PA)' 'IENTr Concurrently with the execution or this Agreement, Defendant shall pay to
<br />Plaintiff, the aggregate suni or wry- 1 1 IOUSAND Dollars ($50,000,00) in a cheep, made
<br />payable to 1\rieC: une Lev Croup, tV1cCune; Wright Arevailo Ve;rcoski kusel Week Brandt APC:
<br />trust account for immediate disbansernent:io Plaintiff Pamela Nelson and any lien holders,
<br />5. GENERAL JLEASE: In consideration or:the mutual general releases contained herein, and
<br />for Cither ood,and valuable consideration, the receipt•of which is acknowledged by each party
<br />hereto, the partiespromise, agree and generally release as follows:
<br />5,1 Except as to such rights or claims as may he created by this Agreement, each party
<br />hereto hereby releases, remises and forever discharges each. other party hereto from any
<br />and all claims, demands and cause of -causes of action c fisting as of the effective date and
<br />arising. out of, connected with or incidental to the .dealings between the parties hereto
<br />prior to. the effective. date hereof mcludmg, without limitation an the generality of the
<br />foregoing, any and all claims, demands and cause or causes of action reflected in the civil
<br />action re.l"creneed in Paragraph, 2.2 above.
<br />Agreement ai'Setile;ritent and General Release.
<br />Page t c F9
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