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1, .PARTIES.: The parties to this Agreement of $ettlement and General Release ("Agreement") <br />are Ebrahim Kazemi ("Plaintiff"), and City of Redlands ("Defendants). <br />2. RECITALS: This Agreementis made with reference to the following facts; <br />2.1 Certain disputes and :controversies have arisen between the parties hereto <br />2.2 Such disputes and controversies include, but are not limited. to, the .olaims, demands <br />and case or causes of.aCtion set forth by the parties hereto in a .civil, action pending in the <br />.San I4ernardino County Superior. Court and entitled Kazeini v. City of Redlands, et al„ <br />Case No. CIVS13.2415609; <br />.2,3. It is.the intention of the parties hereto to settle and dispose of„ 'hilly and completely, <br />any aridafl deinands and 041180 or causes of action existing as of the effective date <br />of this .agreement andarising out of, connected with, or incidental to the dealings between <br />parties hereto to the effective.date hereofincluding, without limitation on the generality <br />ofthe foregoing, any and all claims, demandsand, cause or muses of action reflected in <br />the civil action referenced in Paragraph 2,2above, <br />DISMISSAL Concurrently .With the eXecution. Of this Agreement, Plaintiff shall dismiss,. with <br />prejudice, the civil referenced in Paragraph, 2.2 above, in exchange for the promises, <br />covenants,..conditions and payments set forth in Paragraph Four. <br />4. PAYMENT: Concurrently with the execution of this Agreement, Defendant shall pay to <br />Plaintiff, the aggregate sum OfPive Hundred Deltas ($500.00) in a check made payable to <br />Milligan, Beswick, Levine & Knox, LLP and Plaintiff.Ebrahim Kazemi. <br />5 :GENERAL RELEASE:: In consideration of the nxutual general releases contained herein, and <br />.for other .gOb4 and Valuable consideration, thereceipt: of which is acknowledged by each party <br />hereto,the parties .prise, agree and generally release as follows: <br />5,1 Except as to 'such rights or olairrxs as may be created by this Alreement, each party <br />hereto hereby iease, remises and forever discharges each other party hereto from any <br />andall ciams, de:bands ,and cause or causes of actiOri eXisting ts ofthe effective date and <br />arising .out of, connected with or in0identa1. to the dealings between the parties 'hereto <br />priOrsto the effectivedate hereof including, without limitation on the generality. of the <br />foregoing, any and all claims, demands and causeor causes of action reflected in the civil <br />aotiorx.referenced in Paragraph, 2.2 above, <br />dement: and GeriettIR <br />Page 1 of 4 <br />