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Settlement Agreement and Release of Claims
<br />Gana Ruan v City of Redlands, et al
<br />California Superior Court of Superior Court of California
<br />County of San Bernardino, Case No CIVDS 1910501
<br />United States Bankruptcy Court for the Central District of California, Riverside Division Case
<br />No 6 18-bk-18347-WJ
<br />A. PARTIES
<br />1 This Settlement Agreement and Release of Claims (hereinafter "AGREEMENT")
<br />is made by, between, and/or on behalf of the following parties
<br />(a) A Cisneros, Trustee of the Bankruptcy Estate of Gina Ruan and Santos
<br />Ruan in United States Bankruptcy Court for the Central District of
<br />California, Riverside Division case number 6 18-bk-18347-WJ
<br />(hereinafter referred to as "PLAINTIFF") on the one hand,
<br />(b) Defendant, Softscapes the Art of Landscaping (hereinafter referred to as
<br />"SOFTSCAPES"), on the other hand,
<br />(c) Defendant, FPA6 Sunset View, LLC, (hereinafter referred to as "FPA6"),
<br />on the other hand, AND
<br />(d) Defendant City of Redlands (hereinafter referred to as "CITY"), on the
<br />other hand
<br />2 PLAINTIFF, SOFTSCAPESFPA6, and CITY are at times collectively referred to
<br />herein as "SETTLING PARTIES" and individually as "SETTLING PARTY "
<br />3 When referred to herein, SETTLING PARTIES, SETTLING PARTY,
<br />PLAINTIFF, SOFTSCAPES,FPA6, and CITY, and each of them, include their heirs, successors,
<br />assignees, designees, attorneys, shareholders, members, partners, officers, directors, managers,
<br />employees, employers, principals, agents, parent companies, subsidiary companies, affiliated
<br />companies, predecessors-m-interest, successors -in -interest, family members, insurers,
<br />subcontractors, materials suppliers, manufacturers, design professionals, engineers, and all other
<br />affiliated entities, persons, and/or agents, whether or not named as a party to this case, except as
<br />expressly set forth herein below
<br />B RECITALS
<br />1 WHEREAS, this matter involves claims of alleged bodily injuries, hospital and
<br />medical expenses, and other related damages, stemming from an alleged slip and fall incident
<br />occurring at or near 1132 Lugonia Ave , Redlands, CA 92374 (hereinafter "SUBJECT
<br />PROPERTY") that occurred on September 8, 2018 ("SUBJECT INCIDENT")
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