HomeMy WebLinkAboutContracts & Agreements_42-2011_CCv0001.pdf SETnEWNT AGREEMENT AND MUTUAL RELEASE
`11-is Settlement Agreement and Mutual Release ("Settlement Agreement") is entered into
by:
Plaintiff: SUSAN LEONARD ("Plaintiff');
Defendants, Cross- CITY OF REDLANDS, VERIZON CALIFORNIA INC., GLOBETEC
Complainants and/or OF CALIFORNIA and MAS TEC NORTH AMERICA, INC.,
Cross-Defendants: ("Settling Defendants");
Plaintiff and Settling Defendants are collectively referred to as the"Parties"and individually
as "Party."'
RECITALS
A. Plaintiff filed a Complaint against Salvador Medina, Salvador Medina, dba Net One
Communications, City of Redlands, Verizon California Inc., Globetee of California, Inc.
(erroneously sued and served as Globetec of California/MasTec North America), MasTec North
America, Inc. (erroneously sued and served as Globetec of California/MasTee North America), and
Does t through 100, inclusive ("Defendants"), in the San Bernardino County Superior Court, State
of California, Case No.: CIV DS914717 ("Complaint"). In the Complaint, Plaintiff sought to
recover monetary damages as a result of alleged personal injuries to Plaintiff that occurred on or
about November 11, 2008, arising out a fall when she hit a pothole while riding her bicycle
westbound on Cypress Avenue approximately forty feet (40') east of Cajon Street in the City of
Redlands, State of California.
B. Defendant Verizon California Inc. has filed a Cross-Complaint against Salvador
Medina, Salvador Medina dba Net One Communications, City of Redlands, Globetec of
Cali fomia/MasTec North America and Roes I through 20, inclusive.
C. Defendants Globetec, of California, Inc. and MasTec North America, Inc. have filed
a Cross-Complaint against Salvador Medina, individually and doing business as Net One
Communications Construction, Net One Communications, a business organization of unknown
form, Net One Communications Construction, Inc., a California corporation, City of Redlands and
Roes I —20, inclusive, as Cross-Defendants.
D. The Complaint and the Cross-Complaints are collectively referred to as the
"Action."'
E. The Parties desire to enter into this Settlement Agreement in order to provide for
certain payments in full settlement and discharge, of all claims which are, or might have been, the
subject matter of the Complaint and the Cross-Complaints, upon the terms and conditions set forth
below.
1031375o 1
RELEASE
1. release and L scharM Irv_the Plaintiff.
Plaintiff completely releases and forever discharges Settling Defendants, and each of their
respective parent companies, subsidiaries, affiliate, divisions or related legal entities, successors-in-
interest, predecessors-in-interest, partners, joint ventures, assigns, shareholders, officers, directors,
past, present and future principals, agents, employees, servants, representatives, and all persons,
firms, associations and corporations connected with them, including without limitation their
insurers, sureties, and attorneys (collectively referred to as "the Releasees") of and from any and all
claims, demands, causes of action, obligations, debts, warranties (implied and/or express);
guaranties; liens, balances, liabilities, demands, damages, lessen, costs (except as set forth in
Paragraph 3 below), attorneys" tees and expenses of every kind and nature whatsoever; known or
unknown, suspected or unsuspected; anticipated or unanticipated, fixed or contingent,; which the
Plaintiff may now have or may hereafter have against Releasees by reason of any matter, cause or
thing arising out of, or in any manner connected with the Complaint or the facts;giving rise to the
Complaint provided, however, that this release does not discharge any obligations undertaken by
the Partiespursuant to the Agreement.
This release shall extend to every type of claim, whether based on a tort, contract or tither
theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be
acquired, on account of, or in any way growing out of the facts giving rine to the Complaint,
including, without limitation, any and all known or unknown claims for bodily and personal injuries
and related claims, such as for loss-of consortium, by Plaintiff, which have resulted or may result
from the alleged acts or omissions of the Settling Defendants.
Plaintiff understands and agrees that the consideration for the release and discharge set forth
above consists of the promise of payments, and Plaintiff further understands and agrees that no
interruption or delay of any payment, or breach,of any payment provision, shall affect the final,
binding effect of;said release and discharge.
Plaintiff acknowledges and agrees that the release and discharge set forth above is a general
release. Plaintiff:expressly waives and assumes the risk of any and all claims for damages which
exist as of this date, but which the Plaintiff does not know or suspect to exist, whether through
ignorance, oversight, error, negligence, or otherwise, and which, if known, would materially affect
Plaintiff-s decision to enter into this Settlement Agreement. Plaintiff further agrees that Plaintiff has
accepted payment of the sums specified herein as a complete compromise of matters involving
disputed issues of law and fact. Plaintiff assumes the risk that the facts or law may be other than
what Plaintiff believes., It is understood and agreed by the parties that this settlement is a
compromise of a doubtful and disputed claim, and the payments are not to be construed as an
admission of liability on the part of the Fettling Defendants,by whom liability is expressly denied.
Plaintiff has had the benefit of legal counsel, and has been advised of, understands; and
knowingly and specifically waives her rights under California Civil Code §1542, which provides as
follows.
2
A GENERAL RELEASE DOES NOT EXTEND► TO
THE CLAIMS WHICH THE CREDITOR DOES
NOT KNOW NOR SUSPECT TO EXIST IN HIS OR
HER FAVOR AT THE TIME OF EXECUTING A
RELEASE, WHICH IF KNOWN BY HIM OR HER
MUST HAVE MATERIALLY AFFECTED HIS OR
HER SETTLEMENT WITH THE DEBTOR.
2. Release and DisebaEge by the Settling Defendants
The Settling Defendants completely release and fore •er discharge each other, and each of
their respective parent companies, subsidiaries, affiliate, divisions or related legal entities,
successors-in-interest, predecessor s-in-interest, partners, joint ventures, assigns, shareholders,
officers, directors, past, present and future principals, agents, employees, servants, representatives,
and all persons, firms, associations and corporations connected with them, including without
limitation their insurers, sureties, and attorneys {collectively referred to as "the Releasees"), of and
from any and all claims, demands, causes of action, obligations, debts, warranties (implied and/or
express), guaranties, liens, balances, liabilities, demands, damages, losses, costs, attorneys' fees and
expenses of every kind and nature whatsoever, known or unknown, suspected or unsuspected,
anticipated or unanticipated, fixed or contingent, which each Settling Defendant may now have or
may hereafter have against Releasees by reason of any matter, cause or thing arising out of, or in
any manner connected with the Complaint and/or any Cross-Complaint or the facts giving rise to
the Complaint and/or any Cross-Complaint in the Action; provided, however, that this release does
not discharge any obligations undertaken by the Parties pursuant to the Agreement.
This release shall extend to every type of claim, whether based on a tort, contract or other
theory of recovery, which each Settling Defendant now has, or which may hereafter accrue or
otherwise be acquired, on account of, or in any way growing out of the facts giving rise to the
Complaint and/or any Cross-Complaint in the Action, including, without limitation, any and all
known or unknown claims for bodily and personal injuries, indemnity, contribution and related
claims, by the Parties, which have resulted or may result from the alleged acts or omissions of the
Settling Defendants.
The Settling Defendants understand and agree that the consideration for the release and
discharge set forth above consists of the promise of payments, and the Settling Defendants further
understand and agree that no interruption or delay of any payment, or breach of any payment
provision, shall affect the final,binding effect of said release and discharge.
The Settling Defendants acknowledge and agree that the release and discharge set forth
above is a general release. The Settling Defendants expressly waive and assume the risk of any and
all claims for damages which exist as of this date, but which the Settling Defendants do not know or
suspect to exist,whether through ignorance, oversight, error, negligence, or otherwise, and which, if
known, would materially affect each Settling Defendant's decision to enter into this Settlement
Agreement. Each Settling Defendant assumes the risk that the facts or law may be other than what
each Settling Defendant believes. It is understood and agreed by each Settling Defendant that this
1031375A
settlement is a compromise of a doubtful and disputed claim, and the payments are not to be
construed as an admission of liability, fault and/or breach on the part of the Settling Defendants,by
whom liability, fault and/or breach are expressly denied.
The Settling Defendants have each had the benefit of legal counsel, and have each been
advised of, understands, and knowingly and specifically waives his or her or its rights under
California Civil Code §1542,which provides as follows:
A GENERAL RELEASE DOES NOT EXTEND TO
THE CLAIMS WHICH THE CREDITOR DOES
NOT KNOW NOR SUSPECT TO EXIST IN HIS OR
HER FAVOR AT THE TIME OF EXECUTING A
RELEASE, WHICH IF KNOWN BY HIM OR HER
MUST HAVE MATERIALLY AFFECTED HIS OR
HER SETTLEMENT WITH THE DEBTOR.
3. Paments.
Settling Defendants agree to pay Plaintiff by checks or drafts the total amount of Thirty
Thousand Dollars and Zero Cents ($30,000.00). Settling Defendants have agreed to contribute
the following sums:
(1) Seventeen Thousand Five Hundred Dollars and Zero Cents ($17,500.00)to be paid
by Verizon California Inc., Globetee of California and MasTec North America, Inc.; and,
(2) Twelve Thousand Five Hundred Dollars and Zero Cents ($12,500.00)to be paid by
City of Redlands.
Upon approval of the settlement by City of Redlands' City Council, Defendants will then
issue their respective checks or drafts and made payable to"Susan Leonard and Law Office of Gary
D. Baughman,APC,"Federal Tax Identification Number 26-3163456.
4. Complete Defense
This Settlement Agreement may be asserted as a complete defense to any claim that may be
brought relating to any released claim made by the Parties in the Action as set forth above.
5. nforcebilii
This Settlement Agreement shall be enforceable as between all Parties notwithstanding the
failure to one or more Parties to execute it. The Parties hereto agree that this Settlement Agreement
shall constitute a "stipulation in writing" pursuant to California Code of Civil Procedure §§664.6
d'664.'7.. At the request of any Party,the Court may enter judgment pursuant to the terms set forth
in the Settlement Agreement, and will retain jurisdiction over the Parties to enforce this Settlement
Agreement in full until its final performance. This includes tolling of any applicable statutes of
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1031375.t
limitations, rules of court or orders, including the five-year dismissal statute for purposes of
enforcement of this Settlement Agreement.
6. Attorneys" Fees and Costs.
Each Party hereto shall bear her, its or their own attorneys' fees and costs arising from the
Action, if any, in connection with the Complaint and/or any Cross-Complaint, this Settlement
Agreement and the matters and documents referred to herein, the filing of the dismissal of the
Complaint, the dismissals of any Cross-Complaint and all related matters.
7. Filing of Dismissals,
Within ten (10) days after execution of this Settlement Agreement by all Parties hereto, and
her upon payment of all cash sums to be paid to Plaintiff hereunder (as set forth in Paragraph 3
above),whichever is later,the following shall occur:
(a) Plaintiff shall file and serve a Request for Dismissal of her Complaint in its entirety
with prejudice and as to all causes of action; and,
(b) All Defendants and Cross-Complainants shall file and serve a Request for Dismissal
of their respective Cross-Complaint,if any,in its entirety with prejudice.
8. Assumption of Liens.
Plaintiff and her attorneys shall be responsible for any and all past, present and
future medical liens, insurance liens, attorney liens and all other liens, actions and/or subrogation
claims (hereinafter collectively referred to as "claims"), known or unknown, which are asserted or
may be asserted, that are filed, brought or submitted by any insurers, health care providers,
attorneys or others against Settling Defendants, their insurers and their attorneys arising out of,
based upon or relating to the alleged acts, omissions or disputes asserted in the Action, and
Plaintiff shall indemnify, defend and hold Settling Defendants, their insurers and their attorneys
harmless, if any such claims are brought against Settling Defendants.
9. Confidentiality.
Plaintiff and Verizon California Inc. Globetec of California and MasTec North America,
Inc. agree that they shall not disclose or publish or cause to be disclosed or published to any entity
or person whatsoever (except their attorneys, officers, accountants, tax advisors, or current, foriner
or prospective insurers) the following: the fact of or contents of the Action, including any and all
facts or allegations contained in any documents, or any facts that led up to the filing of the Action,
the fact of settlement, amount of settlement and/or the content of the terms of this Settlement
Agreement, and the discussions and circumstances preceding the Settlement Agreement.
10. No Prior Assignments or Transfers.
The Parties executing this Settlement Av
,reement each represent and warrant that there has
been no assignment or other transfer of any claim or causes of action which they are releasing
pursuant to the terms of this Settlement Agreement,except as expressly stated herein.
5
1031375,1
11., Covenant Not To;Sue;
In consideration of the payment of the settlement sum, the Parties hereto represent
and warrant that each will forever refrain,from instituting and prosecuting a lawsuit against any
ether Party hereto for anythingrelating to the released claims except as related to the enforcement of
this Settlement Agreement.
1 . No Admission of Liabilihr.
In entering into this Settlement Agreement, no Party is admitting the sufficiency of any
claims, allegations,assertions, contentions, or positions of any other Party,nor the sufficiency of the
defense to any such claims, allegations, assertions,contentions, or positions. By settling, it is not to
be construed that any Party is admitting liability and, in fact to the contrary, each Party hereto
expressly denies any liability on his,their or its part.
13 Good Faith Settlement
The Parties agree, acknowledge and stipulate that the settlement being entered into herein is
in good faith under the provisions of California Code of Civil Procedure, §§877 and 877.6 A
necessary, the Parties further agree to cooperate and enter a Stipulation or prepare other papers for
submission to the Court for its Order thereon that the settlement being entered into herein is in good
faith.
14. integrated Agreement
This Agreement embodies the entire Settlement Agreement and supersedes all other
settlement agreements of the Parties concerning the resolution of all disputes between Plaintiff and
Settling Defendants, and by and between the Settling Defendants relating to the issues identified in
the released claims and the terms and conditions contained herein shall inure to the benefit of and
be binding upon,the heirs, representatives, successors and assigns of each of the Parties hereto.
15. Captions and Interpretations.
The paragraph titles or captions are inserted in this Settlement Agreement as a matter of
convenience. As such,the paragraph titles or captions are not intended to'define, limit or describe
the scope of any provision.
16. Enforcement of Agreement.
A breach of this Settlement Agreement by any one or more Parties does noir affect the
enforceability of applicability of this Settlement Agreement as to the other, or non.-breaching Party
or Parties.
17 Representation of Comprehension of Document
In entering into this Settlement Agreement, the plaintiff represents that she has relied upon
the advice of her owe attorneys, that the terms of this Settlement Agreement have been read. by
6
1031375A
Plaintiff and completely explained to Plaintiff by her attorneys; and that the terms of this Settlement
Agreement are fully understood and voluntarily accepted by Plaintiff.
Plaintiff acknowledges that her decision to enter into this Settlement Agreement is not based
on any statement, wTiting, or representation by any Releasee, or by any of their representatives or
attorneys, regarding the effects or consequences of this Settlement Agreement under the tax laws,
government benefits laws, or other laws of any jurisdiction.
In entering into this Settlement Agreement, each Settling Defendant represents that it has
relied upon the advice of its own attorneys; that the terms of this Settlement Agreement have been
understood and completely explained to each Settling Defendant by its attorneys; and that the terms
of this Settlement Agreement are fully understood and voluntarily accepted by each Settling
Defendant.
Each Settling Defendant acknowledges that its decision to enter into this Settlement
Agreement is not based on any statement, writing, or representation by any Releasee, or by any of
their representatives or attorneys, regarding the effects or consequences of this Settlement
Agreement under the laws of any jurisdiction.
18. Warranty of Authorized Signatories.
Each of the signatories hereto warrants and represents that he or she is competent and
authorized to enter into this Settlement Agreement on behalf of the Party for whom he or she
purports to sign, and each agrees to defend, indemnify, and hold harmless each other Party against
each claim, suit or demand, including necessary expenses of investigation and reasonable attorneys!
fees, in which it may be asserted that he or she was not competent and/or not so authorized to
execute this Settlement Agreement and receive the consideration therefore.
19. Additional Documents.
All Parties agree to cooperate fully and execute any and all supplementary documents and to
take all additional actions which may be necessary or appropriate to give full force and effect to the
basic terms and intent of this Settlement Agreement.
20. Entire Agreement and Successors in Interest.
This Settlement Agreement contains the entire agreement among the Parties hereto with
regard to the matters set forth in it and shall be binding upon and inure to the benefit of the
executors, administrators,personal,representatives, heirs, successors, and assigns of each.
I. Governing La v,
This Settlement Agreement shall be interpreted in accordance with and governed in all
respects by the laws of the State of California.
103 1375,1
22. Sevverabilily.
If any provision or any part of any provision of this Settlement Agreement shall for any
reason be held to be invalid, unenforceable or contrary to public policy or any lava, then the
remainder of this Settlement Agreement shall not be affectedthereby.
f
t
23. Effective Date.
This Settlement Agreement shah be effective on the date it has been signed by all Parties.
24. Counterpa
This Settlement Agreement may be signed by the parties in counterparts, and each signed
counterpart shall become part of the final Settlement Agreement and shall have the same force and
effect thereof. A copy of any signature on a signature page shall be as valid and binding as a
original signature. ;
Dated: " 2011
Susan.Leonard
ff
Plainti _.
CITY OF REDLANDS
By,
Its; (rift)
i
GLOBETEC OF CALIFORNIA
DATED , tll1
By; Nam)
Its: Mile)
S TEC NORTH AMERICA,A, INC.
DATED: 2011
By:
Its: (rias)
8
1031375.1
22. Severabi!ftj
If any provision or any part of any provision of this Settlement Agreement shall for any
reason be held to be invalid, unenforceable or contrary to public policy or any law, then the
remainder of this Settlement Agreement shall not be affected thereby.
23. Effeelfte DaLe.
This Settlement Agreement shall be effective on the date it has been signed by all Parties.
24. CounteMIE!j.
This Settlement Agreement may be signed by the parties in counterparts, and each signed
and
counterpart shall become part of the faW Settlement Agreement and shall have the same force
effect thereof. A copy of any signature on a signature page shall be as valid and binding as an
Original signature.
Dated- )2011
Susan Leonard
Plaintiff
CITY OF DLANDS
DATED: March 2 2011
BY: Pete Aguilar
Its. Mayor, City of Redlands critic)
GLOBETEC OF CALIFORNIA
DATED: 2011
By:
Its, (ride)
TMAS TEC NORT14 AMERICA,INC.
DATED: J 2011
By: (Pririt Name)
Its:
1331375.1
2. Severabifill.
If any provision or any part of any provision of this Settlement Agreement Shall for any
reason be held to be invalid, unenf6rceable or contrary to public policy or any lave, then the
remainder of this Settlement Agreement l not be affected thereby.
23. E_ffec&e Date.
This Settlement A e t shall be effective on the date it has been signedby all
24. Countmarts.
This Settlement Agreement<may be signed by the parties in counterparts, and each signed
counterpart shall become part of the Settlement Agreement and shall have the same force
effect thereof A copy of any signature on a sigmAure page shall be as valid and binding as an
original i
Dat2011ed:
Susan Leonard
Plaintiff
CITY OF REDLANDS
DATED: 2011
By tN
Its: (Title)
GLOBETEC CE CALIFORNIA
DATED: Aukll�- A"' ,2011
Ey: L G t r
Its
S TEC NORTH AMERICA,INC,
DATED: yh , . 11, Ali,
Its: µ (Title)
8
1031375.1
'ERIZON CALIFORNIA INC.
DATED; 2011
By; (print
its: , , (cidl:)
APPROVED AS TO FORM AND CONTENT:
LA's OFFICE OF GARY D,BAUGHMAN,APC
DATED: ,2011
Gary D.Baughman,Esq.
a-
Attorneys for Plaintiff',
SUSAN LEONARD
KRsXLE, RODIG R AND SPRIGGS
DATED; ,2011_
Bruce E.Disenho use, Esq.
Attorneys for Defendant and Cass-Defendant CITY
OF REDLANDS
Y
WILSON,ELSER,MOSKOWITZ, �.
EDELMAN&DICKER LLP
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DATED: ,`2011
Peter R.Bing,Esq.
Attorneys for Defendants and.Cass-Complainants
GLOBETEC OF CALIFORNIA and MAS TEC
NORTH AMERICA, INC. and defendant`
VE.RI ON CALIFORNIA INC,
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VER.IZQN CALIFORNIA INC.
DATED: , 2011
By: 01fim Nam)
Its:
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Its: (ride)
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APPROVED AS TO FORM AND CONTENT:
LAW OFFICE OF GARY D. BAUGHMAN,APC
DATED: 2011
Gary D
-Bafig)vnan,Aq.
Attorneys for Plaintiff,
SUSAN LEONARD
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KINKLE,RDDIGER AND SPRIGGS
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DA .2011 rt
Bruce E. Di arse,Esq.
Attorneys for Defendant and Cross-Defendant CI.
OF REDLANDS
WILSON,EL ER,MOSI OWI TZ,
EDELMAN&DICKER LLP 3:
DATED. __ ,2(111
Peter R. Bing,Esq.
Attorneys for Defendants and Cross-Complainants
GLOBETEC OF CALIFORNIA and MAS TEC
NORTH AMERICA, INC. and Defendant
UE DI's CALIFORNIA INC.
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Its. (rift)
APPROVED AS TO FORM AND CGN'I'EN'I'
LAW OFFICE OF GARY D.BAUGHMAN,APC
DATED: .2011
Gary D.Baughman,Esq._
Attorneys for Plaintiff,:
SUSAN LEONARD
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f3I]►IGER S1RIGGS
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DATED: , 011
Brame E.Dis ous ,Esq.
Attorne s far Defeo t and Cross-Defendant CITY
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OF L S
WILSON,ELSER,MOSKOWITZ,
EDELMAN&DICKER LLP ;
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DATED: 2011
Peter R. fling,
Attorneys for Defendants and Cross-Complainants,
GLOBETEC OF CALIFORNIA and MAS TEC
NORTH AMERICA, INC, and: Defendant �
VERIZON CALIFORNIA INC,
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VERIZON CALIFORNIA INC.,
DATED: 2011
By: (PrintNwne)
Its: (Titte)
APPROVED AS TO FORM AND CONTENT:
LAW OFFICE OF GAR'"t'" O, BAUGHMAN, AIDC
DATED: ,2011
Gary D. Baughman, Esq.
Attorneys for Plaintiff,
SUSAN LEONARD
KrNKLE, R.ODfGER AND SPRIGGS
DATED: , 2011
Brace E. Disenhornse, Esq.
Attorneys for Defendant and Crass-Defendant CITY'
OF REDLANDS
EDELMAN& DICKER LLP
DATED: ( , 2411 1
Peter Rm Bing,Esq.
Attorneys for Defendants an Cross-Complainants;
GLOBETEC OF CALIFO NIA and MAS TEC
NORTH AMERICA, I TC. and, Defendant
VERIZON CALIFORN � C'
1031375A
LAW OFFICES OF.
C.U1LI ERMO W SCHNA40ER. K1NKLE, RODIGER AND SPRIGGS L.9 A:W4E.LEt.C-tv Oy f,C&..
A'1.PYKA. PROFESSIONAL CORPORATION 880.$OUT. FoaUEROA ST"CE.T
DAVID P. LENHARDI SUrTE 1OOO
BRUCE E.oss"NousE 3333 FOURTEENTH'STREET LO*A.41LES,CALcFaa—.90017
SCOTT B SPRIGGS RIVERSIDE,CALIFORNIA 93507 42131 029.12,51.
BON H,TELL FAX 12131 020.8382.
MICHAEL F MOON TELEPHONE(951) 6@3-341x7
EVELYN LEVINE SOLIS
MISTY W.TURCO FAX:.( 51)683-7759 75.90..o% CauwTv OFFICE:
ARISTA F. nAWKINS P,O.BOX 1558
DANIEL ) KO:LC2 KRSRRB KRSATTYS-R1V,COM: 837 NBRTM Ross STREET
WESLEY U.HELLERUD SANTA AWA.CAL:IFOANIA :02101:
ROBERT E SUT"TL E:
47 141 a35-4#d rh
ELIZABETH 5..:.WARRE74 FAX 131A}:687.700
COLIN A.NORTHCUTT
March 30, 70111
. IN REPLY:REFER TO
.UR YALE:
RIS'-2 f1 7-2
City of Redlands'
35 Cgjon Street, Suite
Post Office Box 3005
Redlands, California 92373
Attention: Dan McHugh,City Attorney
APR
Your File: 1Jrtknowvrt
%-LIVED
Insured: City of Redlands ' °£ =° '
Claimant, Susan Leonard
Loss Late: November 11, 2008
Lear Mr. McHugh-
We
icHu hWe have received the fully executed Settlement Agreement and Mutual Release for this
ease and attach the original hereto Please provide our office with the settlement funds of
$12,300.00. We will forward the settlement funds to plaintiff s attorney. We will provide you
with a copy of the, conformed Request for Dismissal upon receipt.
Should you have any questions or wish to discuss this matter further, please do not
hesitate to contact the undersigned. In the interim, we will continue: to keep you apprised of all
developments as they occur.
Yours
I IN L , )DIGER AND S RIGG
.fession l orpor iota
ruce E.
isenhouse
l El /pia
Enclosures