HomeMy WebLinkAboutContracts & Agreements_82-2026SETTLEMENT AGREEMENT AND RELEASE OF CLAIMS
This Settlement Agreement and General Release ("Agreement") is entered into between
the City of Redlands ("DEFENDANT" or "CITY"), its past or present council members, directors,
governing body, employees, agents, predecessors, attorneys, divisions, departments,
representatives, insurers, successors in interest and assigns, and all persons acting by, through,
under, or in concert with any of them, on the one hand, and Geneva Holzer ("PLAINTIFF") on the
other. DEFENDANT and PLAINTIFF are collectively referred to as the "PARTIES" or
individually as a "PARTY" with reference to the following:
RECITALS
A. PLAINTIFF is employed by DEFENDANT as a Forensic Specialist;
B. PLAINTIFF's employment with DEFENDANT will end no later than the Effective
Date of this Agreement, due to her voluntary resignation from her position;
C. PLAINTIFF filed a complaint with the California Civil Rights Department
("CRD")/Equal Employment Opportunity Commission ("EEOC") against DEFENDANT
(hereinafter "Administrative Charges") alleging she was harassed and discriminated against based
on her gender and retaliated against because she reported harassment and discrimination, and the
CRD issued PLAINTIFF a Right to Sue notice dated May 17, 2023;
D. On September 20, 2023, PLAINTIFF filed a lawsuit against DEFENDANT in the
San Bernardino County Superior Court, Case No. CIVSB2322787 ("LAWSUIT"), alleging (1) sex
and gender discrimination in violation of Government Code, section 12940, subdivision (a); (2)
hostile work environment in violation of Government Code, section 12940, subdivision 0); (3)
retaliation in violation of Government Code, section 12940, subdivision (h); (4) retaliation in
violation of Labor Code, section 1102.5; and (5) failure to prevent discrimination and harassment
in violation of Government Code, section 12940, subdivision (k), and seeking damages for her
physical and emotional injuries as alleged in her lawsuit and discovery;
E. On February 13, 2026, PLAINTIFF filed a Verified Petition for Writ of Mandamus,
Prohibition and/or Extraordinary Relief ("WRIT") seeking to set aside and vacate the Superior
Court's ruling on PLAINTIFF'S Pitchess motion, which was filed on November 25, 2025 and
denied in its entirety on January 8, 2026;
F. DEFENDANT categorically denies any and all of the claims and allegations
asserted by PLAINTIFF against DEFENDANT, but has incurred significant fees and costs as a
result of PLAINTIFF'S LAWSUIT and therefore wishes to avoid incurring additional litigation
expenses;
G. This Agreement is intended to be a full, complete, and final settlement of each and
every claim, cause of action, appeal, or liability, whether known or unknown, PLAINTIFF may
have or may have had against DEFENDANT prior to and up through the Effective Date of this
Agreement, including, but not limited to the Administrative Charges, and the LAWSUIT and any
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other claims by PLAINTIFF arising out of, or in any way related to PLAINTIFF'S employment
with the DEFENDANT and/or separation from such employment.
NOW THEREFORE, and in consideration for the promises contained herein, and other
good and valuable consideration, receipt of which is acknowledged by the execution of this
Agreement, and to avoid unnecessary litigation, it is agreed by and between the PARTIES as
follows:
L WAIVER AND RELEASE
A. No Admission of Liability. This Agreement and compliance with this
Agreement shall not in any way be construed as an admission by DEFENDANT or PLAINTIFF
of the truth of any allegations, or an admission of any unlawful acts or other liability whatsoever
against each other or against any other person or entity. DEFENDANT and PLAINTIFF
specifically disclaim any liability to, against each other, or against any other person or entity, on
the part of themselves, any related person or any related predecessor corporation or its or their
agents, representatives or successors in interest and assigns. This Agreement cannot be used by
a PARTY to,demonstrate any admission of liability or wrongdoing by another PARTY.
B. Plaintiffs Release of Claims. PLAINTIFF hereby and forever releases and
discharges DEFENDANT, and any past and/or present parent, subsidiary, and/or affiliated entities,
as well as any past and/or present direct or indirect successors, officers, officials, current and
former directors, current and former trustees, heirs, predecessors, assigns, agents, insurers,
employees, lay volunteers or representatives, attorneys and representatives, of each and every
party, and each of them, past and present ("Releasees"), from any and all causes of action,
judgments, liens, indebtedness, damages, losses, claims, liabilities, and demands of whatsoever
kind or character, known or unknown, suspected to exist or not suspected to exist, anticipated or
not anticipated, whether or not it has been brought before any state or federal court or before any
state or federal agency or other governmental entity, including, but not limited to, all of
PLAINTIFF's claims arising from or related or attributable in whole or in part to PLAINTIFF's
application for employment and employment relationship with DEFENDANT, whenever those
claims may have occurred.
PLAINTIFF understands and agrees that this Agreement extends to all disputes or claims
of every nature and kind, known or unknown, suspected or unsuspected, past, present, or future,
arising from or attributable to the above -referred matters and disputes. PLAINTIFF understands
and expressly agrees that this Agreement also extends to any other matter, event, or claim
occurring prior to the date of execution of this Agreement.
PLAINTIFF understands and agrees that she is waiving any rights she has, may have had,
or may have, to pursue any and all remedies available to her under any employment -related or
other cause of action against Releasees, including, without limitation, any claims for
discrimination, harassment and/or retaliation, claims under the California Fair Employment and
Housing Act (California Government Code section 12900, et seq.), the California Family Rights
Act (California Government Code section 12945.2), the Unruh and George Civil Rights Acts
(California Civil Code section 51, et seq.), all provisions of the California Labor Code and any
wage orders or similar directives or authorities issued by any federal or state authority having
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enforcement powers, the Constitution of the United States, the Constitution of the State of
California, Title VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000e, et seq.), the Age
Discrimination in Employment Act (29 U.S.C. § 621, et seq.), the Equal Pay Act (29 U.S.C. §
206(d)), the Fair Labor Standards Act (29 U.S.C. § 201, et seq.), the Family and Medical Leave
Act (29 U.S.C. § 2601, et seq.), the Employment Retirement Income Security Act of 1974 (29
U.S.C. § 1001, et seq.), Sections 1981-88 of Title 42 of the United States Code (42 U.S.C. § 1981,
et seq.), the American with Disabilities Act (42 U.S.C. § 12101, et seq.), claims of retaliation or
whistle -blowing (including but not limited to California Labor Code section 1102.5, et seq, and
Government Code section 12653), claims for breach of any type of contract, including written,
oral or implied and, including, but not limited to the Contract, breach of any covenant, promise or
representation pertaining to PLAINTIFF's employment, whether expressed or implied, and all
other claims arising in contract, tort or equity or under any other statute, whether federal, state or
local up to the date of execution of this Agreement (collectively referred to as "Released Claims").
This Agreement does not limit PLAINTIFF's ability to bring an administrative charge with
an administrative agency, but PLAINTIFF expressly waives and releases any right to recover any
type of personal relief from the DEFENDANT, including monetary damages or reinstatement, in
any administrative action or proceeding, whether state or federal, and whether brought by
PLAINTIFF or on PLAINTIFF'S behalf by an administrative agency, related in any way to the
matters released herein. Furthermore, nothing in this Agreement prohibits PLAINTIFF from
reporting possible violations of law or regulation to any government agency or entity, including
but not limited to the Equal Employment Opportunity Commission, the California Civil Rights
Department, the Department of Labor and/or the Department of Justice, or malting other
disclosures that are protected under the whistleblower provisions of law. PLAINTIFF does not
need prior authorization of the DEFENDANT to make any such reports or disclosures and is not
required to notify the DEFENDANT that she has made such reports or disclosures.
C. Civil Code Section 1542 Waiver. PLAINTIFF hereby waives any and all rights
that she may have pursuant to California Civil Code Section 1542, which reads as follows:
A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS
THAT THE CREDITOR OR RELEASING PARTY DOES
NOT MOW OR SUSPECT TO EXIST IN HIS OR HER
FAVOR AT THE TIME OF EXECUTING THE RELEASE
AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE
MATERIALLY AFFECTED HIS OR HER SETTLEMENT
WITH THE DEBTOR OR RELEASED PARTY.
PLAINTIFF hereby expressly waives the provisions of California Civil Code Section
1542 and further expressly waives any right to invoke said provisions now or at any time in the
future. PLAINTIFF recognizes and acknowledges that factors which have induced her to enter
into this Agreement may turn out to be incorrect or to be different from what she had previously
anticipated, and she hereby expressly assumes any and all of the risks thereof and further
expressly assumes the risks of waiving the rights provided by California Civil Code Section
1542.
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D. Release of All Claims Pursuant to Any MOU. PLAINTIFF hereby expressly
waives any and all claims now and forever that she has or may have to rights or benefits pursuant
to the Memorandum of Understanding ("MOU") between the City of Redlands and the Redlands
Civilian Safety Employee Association, covering the years 2017 through 2023, the Memorandum
of Understanding between the City of Redlands and the Redlands Civilian Safety Employee
Association, covering the years 2023 through 2026, or any other MOUs between the City of
Redlands and the Redlands Civilian Safety Employee Association. PLAINTIFF also hereby
expressly waives all claims now and forever that she has or may have that are or would be pursued
by the Redlands Civilian Safety Employee Association with the Public Employment Relations
Board ("PERB"). Moreover, PLAINTIFF specifically acknowledges and agrees that she waives
any and all voting rights she may believe she has or she may have regarding any current or future
Redlands Civilian Safety Employee Association claims, issues, matters and/or PERB charges or
matters.
E. Age Discrimination in Employment Act Waiver and Release. The Age
Discrimination in Employment Act of 1967 ("ADEA") makes it illegal for an employer to
discharge any individual or otherwise discriminate with respect to the nature and privileges of an
individual's employment on the basis that the individual is age forty or older. The Older Workers
Benefit Protection Act ("OWBPA"), 29 USC. §§ 626, et. seq. further augments the ADEA and
prohibits the waiver of any right or claim under the ADEA unless the waiver is knowing and
voluntary. By entering into this Agreement, PLAINTIFF acknowledges that she is knowingly and
voluntarily, for just compensation in addition to anything of value to which PLAINTIFF is already
entitled, waiving and releasing any rights she may have under the ADEA and/or OWBPA.
PLAINTIFF further acknowledges that she has been advised and understands, pursuant to the
provisions of the ADEA and OWBPA, that:
1. This waiver/release is written in a manner understood by PLAINTIFF.
2. PLAINTIFF is aware of and has been advised of her rights under the ADEA
and OWBPA, and of the legal significance of her waiver of any possible claims
she currently may have under the ADEA, OWBPA, or similar age
discrimination laws.
3. PLAINTIFF is entitled to a reasonable time of at least twenty-one (21) days
within which to review and consider this Agreement, and the waiver and release
of any rights she may have under the ADEA, the OWBPA, or similar age
discrimination laws, but she may, in the exercise of her own discretion, sign or
reject this Agreement at any time before the expiration of the twenty-one (21)
days.
4. The waivers and releases set forth in this Agreement shall not apply to any
rights or claims that may arise under the ADEA and/or OWBPA after the date
this Agreement takes effect.
5. PLAINTIFF was advised and by this Agreement is advised in writing to that
she should consult with an attorney prior to executing this Agreement.
PLAINTIFF has had an opportunity to discuss this waiver and release with, and
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to be advised regarding this Agreement, by an attorney of her choice, and does
not need any additional time within which to review and consider this
Agreement.
6. PLAINTIFF has seven (7) days following her execution of this Agreement to
revoke the Agreement by submitting a written revocation addressed via email
to Mark H. Meyerhoff of Liebert Cassidy Whitmore at
mmeyerhoffc lewlegal.com.
PLAINTIFF knowingly and voluntarily agrees to all of the terms set forth in
this Agreement and knowingly and voluntarily intends to be bound by those
terms.
PLAINTIFF ACKNOWLEDGES BY HER SIGNATURE TO THIS AGREEMENT
THAT SHE FULLY UNDERSTANDS HER RIGHT TO DISCUSS THIS WAIVER WITH
LEGAL COUNSEL, AND HAS CAREFULLY READ AND FULLY UNDERSTANDS THE
WAIVER, AND THAT SHE IS VOLUNTARILY AGREEING TO WAIVE ANY CLAIMS
THAT SHE HAS OR MAY HAVE UNDER THE AGE DISCRIMINATION IN
EMPLOYMENT ACT, THE OLDER WORKERS BENEFIT PROTECTION ACT, AND
ANY OTHER LAWS PROHIBITING AGE DISCRIMINATION IN EMPLOYMENT
ARISING FROM OR RELATED OR ATTRIBUTABLE TO THE PARTIES'
ALLEGATIONS OR CLAIMS.
F. Effective Date. The Effective Date of this Agreement shall be the last date on
which all of the following occurs: (1) all PARTIES have signed this Agreement; (2) this
Agreement has been fully approved by DEFENDANT'S City Council as specified in Section
III(A) below; and (3) the seven-day revocation period has expired without receipt of any revocation
as set forth in Section I(E)(6) above.
G. Representation of No Pending Claims. PLAINTIFF represents that, other than the
claims described herein, she has not filed any lawsuits, complaints, appeals, claims, applications,
or charges against the DEFENDANT or the Releasees with any state or federal court, or local, state
or federal agency, or administrative or quasi -administrative tribunal or person, based on any events
occurring on or prior to the date of execution of this Agreement.
II. PAYMENT AND DISMISSAL
The PARTIES agree that following full execution of this Agreement, the PARTIES shall
perform the following acts:
A. Immediately upon executing this Agreement, PLAINTIFF will withdraw in writing
and cause to be dismissed with prejudice in its entirety the WRIT and any and all complaints,
charges, or claims against DEFENDANT regardless of whether they are specifically referred to
herein.
B. PLAINTIFF and/or her counsel, Wagner Zemming Christensen LLP, shall sign and
forward to DEFENDANT'S attorneys, Liebert Cassidy Whitmore, Mark H. Meyerhoff, 6033 W.
Century Boulevard, 5th Floor, Los Angeles, CA 90045, a request for dismissal of the LAWSUIT
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with prejudice. Liebert Cassidy Whitmore shall not file the dismissal until payment of the
Settlement Proceeds occurs, as described below. The payment of Settlement Proceeds is contingent
on Liebert Cassidy Whitmore's receipt of the request for dismissal with prejudice of the Lawsuit.
C. DEFENDANT shall pay PLAINTIFF the total sum of four hundred seventy five
thousand dollars ($475,000.00) (the "Settlement Proceeds"). The Settlement Proceeds shall be
made payable in two checks as follows: (1) The first check shall be made payable to Geneva Holzer
in the amount of $257,764.79, allocated to alleged non -wage damages and reported on IRS Form
1099; (2) The second check shall be made to Wagner Zemming Christensen LLP in the amount of
$ 217,235.21 for PLAINIFF'S costs and attorney fees, with the amounts to be reported on Form
1099 as required by law. DEFENDANT shall transmit the settlement payment to PLAINTIFF's
counsel within 15 days of the Effective Date of this Agreement, provided that: (1) PLAINTIFF or
Wagner Zemming Christensen LLP have tendered the signed request for dismissal and (2)
DEFENDANT has received completed W-9s forms for both PLAINTIFF and PLAINTIFF's
counsel.
D. PLAINTIFF will voluntarily resign from her employment, effective on the
Effective Date of this Agreement. Simultaneously with PLAINTIFF'S' execution of this
Agreement, she shall sign and return the Letter of Resignation attached hereto. Prior to the
effective date of PLAINTIFF'S resignation, she will be placed on voluntary paid administrative
leave, effective immediately unless PLAINTIFF executes the Agreement on or after May 21, 2026,
in which case the paid administrative leave will be effective May 28, 2026. PLAINTIFF will
remain on paid administrative leave until the Effective Date of this Agreement. During
PLAINTIFF'S paid administrative leave, PLAINTIFF shall not return to the workplace.
PLAINTIFF acknowledges and agrees that upon the Effective Date of this Agreement,
PLAINTIFF'S resignation is deemed accepted by DEFENDANT, is irrevocable, and is not subject
to being set aside by any judicial or administrative action, none of which shall be instituted by
PLAINTIFF. DEFENDANT agrees that no adverse note or comment shall be placed in
PLAINTIFF'S personnel file relating to PLAINTIFF'S resignation or any other matter without
notification of PLAINTIFF and her counsel, other than the necessary documentation indicating
that she resigned. DEFENDANT will not place any comments in her personnel file that indicate
PLAINTIFF is ineligible for rehire.
III. GENERAL PROVISIONS
A. City Council Approval. The PARTIES understand and agree that this Agreement
is contingent upon approval by the City of Redlands' City Council and will not become effective
and enforceable unless and until the City Council approves the Agreement.
B. No Representation of Tax Liabilities. No PARTY, including the attorneys for any
PARTY, has made any representations or warranties regarding whether the Settlement Proceeds
are subject to taxation. DEFENDANT does not bear any responsibility for tax liability that may
arise as a result of the Settlement Proceeds. PLAINTIFF agrees to assume any responsibility for
payment of taxes for any of the Settlement Proceeds. PLAINTIFF agrees to indemnify and hold
the EMPLOYER and all RELEASEES harmless from any and all tax liability which may become
due as a result of the Settlement Proceeds under this Agreement and/or for any liability that may
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be incurred as a result of any dispute over payment of the Settlement Proceeds arising between
PLAINTIFF and PLAINTIFF'S attorneys.
C. Materials Produced Pursuant to Protective Order. Pursuant to the agreed upon
Stipulated Protective Order, DEFENDANT and PLAINTIFF shall destroy or return to the
producing Party all copies of all documents designated "Confidential" that have been produced
during the discovery process of the Lawsuit which are in their possession, custody, or control. The
Parties and their attorneys will also recover any and all copies of these documents that they
distributed to third parties and shall destroy or return those to the producing Party.
D. Each Party to Bear Own Fees and Costs. Aside from what is specifically provided
for in this Agreement, each PARTY shall bear their own costs, expenses and attorneys' fees
incurred in connection with the proceedings and/or events resulting in and/or preceding this
Agreement, or in connection with any other claims made or investigated by either PARTY against
the other in any forum (civil, criminal, administrative or quasi -administrative), and each of the
PARTIES hereto expressly waive any claim for recovery of any such costs, expenses or attorneys'
fees from the other PARTY. Attorneys for all PARTIES to this Agreement do likewise expressly
waive any claim for recovery of costs, expenses and/or attorney's fees from the opposing PARTY.
Neither PARTY shall be deemed a "prevailing party" by virtue of executing this Agreement.
E. No Prior Assignments. PLAINTIFF represents that she has not assigned or
transferred, or purported to assign or transfer, to any person or entity, any claim or any portion
thereof or interest therein against DEFENDANT.
F. Enforcement. This Agreement is made and entered into in the State of California,
and shall be governed, interpreted, and enforced under the laws of the State of California, without
regard to any conflicts -of -laws principles that would require the laws of any other jurisdiction to
apply. The PARTIES agree that jurisdiction and/or venue of any action involving the validity,
interpretation, or enforcement of this Agreement or any of its terms, provisions, or obligations, or
claiming breach thereof, shall exist exclusively in a court or government agency located within the
County of San Bernardino, State of California. The PARTIES further agree that this Agreement
may be used as evidence in any subsequent proceeding in which any of the PARTIES allege a
breach of this Agreement or seek to enforce its terms, conditions, provisions, or obligations.
G. Covenant to Effectuate Agreement. Each PARTY hereto agrees to do all things
and execute and deliver all instruments and documents necessary to fulfill and effect the provisions
of this Agreement and to protect the respective rights of the PARTIES to this Agreement.
H. Covenant Not to Sue. To the extent permitted by applicable law, PLAINTIFF
promises not to file any lawsuits in any court, or any demand for arbitration, against any of the
Releasees as it relates to any Released Claims.
I. Waiver of Terms of Agreement. No waiver by any PARTY of any breach of any
term or provision of this Agreement shall be construed to be, nor be, a waiver of any preceding,
concurrent or succeeding breach of the same, or any other term or provision hereof. No waiver
shall be binding unless in writing and signed by the PARTY to be charged or held bound. It is
further understood and agreed that if, at any time, a breach of any term of this Agreement is
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asserted by any PARTY hereto, that PARTY shall have the right to seek specific performance of
that term and/or any other necessary and proper relief, including, but not limited to, damages.
J. No Duress or Undue Influence. The PARTIES represent and agree that they have
carefully read and fully understand all of the provisions of this Agreement, and that they are
voluntarily, without any duress or undue influence on the part of or on behalf of any PARTY,
entering into this Agreement.
K. Consultation with Counsel. The PARTIES affirm that, prior to execution of this
Agreement, they have consulted with their respective legal counsel/representatives concerning the
terms and conditions set forth herein, and that they understand the advice provided to them.
L. Entire Agreement. This Agreement contains all of the terms and conditions agreed
upon by the PARTIES hereto regarding the subject matter of this Agreement. Any prior
agreements, promises, negotiations, or representations, either oral or written, relating to the subject
matter of this Agreement, not expressly set forth in this Agreement, are of no force or effect. This
Agreement may not be modified unless agreed to and signed by the PARTIES.
M. Interpretation. This Agreement has been jointly negotiated and drafted by the
PARTIES. The language in this Agreement shall be construed as a whole according to its fair
meaning and not strictly for or against any of the PARTIES. Captions and headings of the sections
and paragraphs of this Agreement are intended solely for convenience, and no provision of this
Agreement is to be construed by reference to the caption or heading of any section or paragraph.
N. Severability. In the event that any one or more provisions of this Agreement shall
be declared to be illegal, invalid, unenforceable, and/or void by a court of competent jurisdiction,
such provision or portion of this Agreement shall be deemed to be severed and deleted from this
Agreement but this Agreement shall in all other respects remain unmodified and continue in force
and effect.
O. No Precedent. This Agreement is in no way intended, and shall in no way be
construed, to restrict rights guaranteed to DEFENDANT under local, state or federal law, rule, policy
or agreement or to establish a precedent in this or any other matter, now or in the future. Nothing in
this Agreement affects any CITY policies, practices, rules, or terms of any applicable collective
bargaining agreement or memorandum of understanding.
P. Non -Disparagement. PARTIES agree not to disparage each other. "Disparage"
as used herein shall mean any communication, oral or written, of false information or the
communication of information with reckless disregard to its truth, or falsity. Nothing in this
Agreement prevents PLAINTIFF from discussing or disclosing information about unlawful acts
in the workplace, such as harassment or discrimination or any other conduct that PLAINTIFF
has reason to believe is unlawful.
Q. Confidentiality and Disclosure of Terms. Except as disclosed herein, the Parties
each agree to maintain the confidentiality of the negotiations underlying this Agreement to the
extent permitted by law, and agree that they shall not voluntarily and publicly discuss the
negotiations that led to this Agreement. This provision shall not extend to any information related
to the negotiations of this Agreement that DEFENDANT may be required to disclose pursuant to
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the requirements of the Ralph M. Brown Act, Government Code section 54950, et seq., the
California Public Records Act, Government Code section 7931.000, et seq., Redlands Municipal
Code Chapter 2.60, or the provisions of any other law or regulation requiring disclosure of
information by public entities.
R. Execution of Counterparts. This Agreement may be executed in one or more
counterparts, each of which shall be deemed an original, but all of which together shall constitute
one and the same instrument. A photocopy or facsimile transmission of the Agreement, including
signatures, shall be deemed to constitute evidence of the Agreement having been executed.
S. Acknowledgement of Full Understanding. PLAINTIFF acknowledges and
agrees that PLAINTIFF has fully read, understands, and voluntarily enters into this Agreement.
PLAINTIFF acknowledges and agrees that PLAINTIFF has had an opportunity to ask questions
and consult with an attorney before signing this Agreement. PLAINTIFF further acknowledges
that PLAINTIFF'S signature below is an agreement to release DEFENDANT and the Releasees
from any and all claims that can be released as a matter of law.
PLEASE READ CAREFULLY. THIS SETTLEMENT AGREEMENT AND
RELEASE INCLUDES A RELEASE BY GENEVA HOLZER OF ALL KNOWN
AND UNKNOWN CLAIMS AS SPECIFIED HEREIN.
IN WITNESS WHEREOF, the Parties hereto have executed the Settlement Agreement and
General Release.
Dated: 5-hl 2 p By:
PI mtiff, Genev Holzer
Dated: p By: �'zo- � ),/
Defendant, City of Kedlands
ATTEST:
Je nne Donaldson, City
4�✓
By: Mario Saucedo
Its: Mayor
13394809.1 RE035-054
LETTER OF RESIGNATION
May 2 -1, 2026
Janice McConnell
Assistant City Manager/Interim Human Resources Director
CITY OF REDLANDS
35 Cajon St., Suite 200
Redlands, CA 92373
jmcconnell@cityofredlands.org
Re: Resignation
Ms. McConnell:
Please accept this as my voluntary and irrevocable resignation from employment with the CITY
OF REDLANDS effective on the Effective Date of this SETTLEMENT AGREEMENT AND
RELEASE OF CLAIMS as set forth in Section I.F.
Very truly yours,
GENEVA HOLZER
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