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DocuSIgn Envelope ID: 6D35908A-D698-46E6-AA56-DFDEADAFEF03 AGREEMENT OF SETTLEMENT AND GENERAL RELEASE 1, PARTIES: The parties to this Agreement of Settlement and General Release ("Agreement") are Julie Scates ("Plaintiff"), and City of Redlands ("Defendants"). 2. .RECITALS: This Agreement is made with reference to the following facts: 2.1 Certain disputes and controversies have arisen between the parties hereto. 2.2 Such disputes and controversies include, but are not limited to, the claims, demands and case or causes of action set forth by the parties hereto hi a civil action pending in the San Bernardino County Superior Court and entitled Julie States v. City of Redlands, et .1„ Case No,' CIVSI '21277g4. 2.3 It is the intention of the parties hereto to settle and dispose of, fully and completely, any and all claims, demands and Cause or causes of action existing as of the effective date of this agreement and.arising out of, connected with, or incidental to the dealings between parties hereto to the effective date hereof including, without limitation on the generality of the foregoing, any and all claims, demands and cause or causes of action reflected in the civil action referenced in Paragraph 2.2 above. • 3, DISMISSAL: Concurrently with the execution of this Agreement, Plaintiff shall dismiss, with prejudice, the civil action referenced in Paragrapb, 2,2 above, in. exchange for the promises, covenants, conditions and payments set forth in Paragraph Four, 4, PAYMENT: Concurrently with the execution of this Agreement, Defendant shall pay to Plaintiff the aggregate sum of NINETY TWO THOUSAND FIVE HUNDRED Dollars ($92,500,00) in a check made payable to the !3eigum, Fry & Van Allen LLP Client Trust Account for disbursement to Plaintiff and any lion holders. Each side shall bear their own fees and costs as part of this settlement. 5. GENERAL RELEASE: In consideration of the mutual general releases contained herein, and for other good and valuable consideration, the receipt of which is acknowledged by each party hereto, the parties promise, agree and generally release as follows: 5,1 Except as to such rights or claims as may created by this Agreement, each party hereto hereby releases, remises and forever discharges each other party hereto from any and all claims, demands and cause or causes of action existing as of the effective date and arising out of, connected with or incidental to the dealings between the parties hereto prior to the effective date hereof including, without limitation on the generality of the foregoing, any and all claims, demands and cause or causes of action reflected in the civil action referenced in.Paragraph 2.2 above. 5.2 Each party to this A.greemerit specifically waives the benefit of provisions of Section Agreement of Settlement and General Release page 1 of 4