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4 <br /> l <br /> AGREEMENT OF SETTLEMENT AND <br /> GENERAL RELEASE <br /> 1. PARTIES: The parties to this Agreement of Settlement and General Release ("Agreement") <br /> are Deborah Guindon ("Plaintiff"), and City of Redlands ("Defendant"). <br /> 2. RECITALS: This Agreement is 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 claims, demands <br /> and case or causes of action set forth by the parties hereto in a civil action pending in the <br /> San Bernardino County Superior Court and entitled Deborah Guindors v. City of <br /> Redlands, et al., Case No. CLADS 1315335 . <br /> 2.3 It is the intention of the parties hereto to settle and dispose of, fully and completely, <br /> any and all claims, demands and cause or causes of action existing as of the effective date <br /> of this agreement and arising out of, connected with, or incidental to the dealings between <br /> parties hereto to the effective date hereof including, without limitation on the generality <br /> of the foregoing, any and all claims, demands and cause or causes of action reflected in <br /> the civil action referenced in Paragraph 2.2 above. <br /> 3. DISMISSAL: Concurrently with the execution of this Agreement, Plaintiff shall dismiss, with <br /> prejudice, the civil action 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 of One Hundred Fifty Thousand Dollars ($150,000), inclusive of all <br /> claims for attorneys fees, costs and medical liens. Each party shall bear their own fees and costs. <br /> 5. GENERAL RELEASE: In consideration of the mutual general releases contained herein, and <br /> for other good and valuable consideration, the receipt of which is acknowledged by each party <br /> hereto, the parties promise, agree and generally release as follows: <br /> 5.1 Except as to such rights or claims as may be 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 or causes of action existing 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 including, without limitation on the generality of the <br /> foregoing, any and all claims, demands and cause or causes of action reflected in the civil <br /> action referenced in Paragraph 2.2 above. <br /> Agreement of Settlement and General Release Page 1 <br />