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SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS <br />This Settlement Agreement and General Release ("Agreement") is entered into between <br />the City of Redlands ("City"), its past and present officers, directors, governing body, employees, <br />agents, predecessors, attorneys, divisions, affiliates, representatives, successors in interest and <br />assigns and all persons acting by, through, under, or in concert with any of them (collectively, the <br />"City"), on the one hand, and Travis Martinez ("Martinez" or "Employee") on the other. The City <br />and Martinez are collectively referred to as the "Parties" or individually as a "Party" with reference <br />to the following: <br />RECITALS <br />A. WHEREAS, Martinez is employed with the City as a deputy chief in the Redlands <br />Police Department; <br />B. WHEREAS, the Parties wish to release the other of any and all claims they each <br />may have against the other, and to amicably end their employment relationship. <br />NOW THEREFORE, and in consideration for the promises contained herein, and other <br />good and valuable consideration, receipt of which is acknowledged by the execution of this <br />Agreement, and to avoid unnecessary litigation, it is agreed by and between the Parties as follows: <br />AGREEMENT <br />1. Recitals. The recitals set forth above are true and correct and are hereby fully <br />incorporated by reference into this Agreement. <br />2. No Precedent. This Agreement is in no way intended, and shall in no way be <br />construed, to restrict rights guaranteed to the City under local, state or federal law, rule, policy or <br />agreement or to establish a precedent in this or any other matter, now or in the future. <br />3. No Admission of Liability. This Agreement shall not in any way be construed to <br />be an admission by the City or Martinez of any unlawful or wrongful acts or other liability <br />whatsoever against each other or against any other person. The City and Martinez specifically <br />disclaim any liability to, or wrongful acts against, each other or against any other person on the <br />part of themselves, any related person or any related predecessor corporation or its or their agents, <br />representatives or successors in interest and assigns. <br />4. Martinez' Retirement and Waiver of Claims. The Parties agree that, in <br />consideration of Martinez' promises as set forth in this Agreement, the City and Martinez will <br />perform the following acts on or after the effective date of this Agreement: <br />1 <br />RE035\053\12811551. v2 <br />