HomeMy WebLinkAboutLech, Diane; 2023-10-25;OocuSig� Envelop.e ID: 5B963425-8671-4FAF-A80B-F2E3ED6F084O
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DocuSign Envelope ID: 58963425-8671-4FAF-A808-F2E3ED6F084O
DocuSig~ Envelop~ ID: 5B963425-8671-4FAF-A80B-F2E3ED6F084D
SETTLEMENT AND RELEASE AGREEMENT
Diane Lech v. City of Carlsbad
San Diego Superior Court Case N o. 37-2020-00042305-CU-PO-NC
Plaintiff intends to release and discharge all claims, demands, rights, including all
appellate rights, and causes of action of any nature even though some of such
damages may not have shown themselves at the time of acceptance of this
Agreement.
4.0 Enforceability
4.1 The Parties acknowledge and agree that the San Diego Superior Court, and in
particular the Judge assigned to this litigation, reta ins jurisdiction over this
Agreement.
5.0 No Admission of Liability
5.1 The Parties acknowledge and agree that this Agreement is in settlement of a
d isputed claim, and no party admits liab il ity or the sufficiency of any claim, cause
of action, o r allegation. This Agreement does not constitute an admission by any
party.
6.0 General Provisions
6.1 This Agreement constitutes the entire understanding of the parties and supersedes
a ll prior agreements.
6.2 This Agreement may not be modified without the wri tten consent of each of the
Parties.
6.3 This Agreement shall be governed in all respects under all applicable federal and
California laws.
6.4 The Parties acknowledge and agree that all Parties participated in the drafting of
this Agreement, and waive any rule of contract interpretation w hich requires or
permits ambiguities in the language or meaning of thi s Agreement to be construed
again st the drafting party.
6.5 If any portion of this Agreement is deemed void, unenforceable, or contrary to
public policy or any law, the remainder of this Agreement shall remain in full
force and effect.
6.6 T his Agreement may be executed in counterparts which shall be considered
together as one Agreement. A fax, photocopy, or emai l signature shall be deemed
the same as an original signature.
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DocuSign Envelope ID: 5B963425-8671-4FAF-A80B-F2E3ED6F084O
SETTLEMENT AND RELEASE AGREEMENT
Diane Lech v. City of Carlsbad
San Diego Superior Court Case No. 37-2020-00042305-CU-PO-NC
6.7 Each undersigned acknowledges and agrees they are authorized to enter into this
Agreement.
DocuSlgned by:
Dated: Octott&/251202~023 --' 0~1~
~fffie~'18t1flC.
APPROVED AS TO FORM ONLY
Martinez & Schill LLP.
Dated: October 24 2023 --' c:J.tnnifer L. Martine~
Attorneys for Plaintiff Diane Lech
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