This Settlement Agreement and Release (?Agreement?) is entered into by and between plaintiff Thomas Bodnar (?Plaintiff on the one hand, and the County of. Riverside (?Defendant?), on the other hand (collectively, the ?Parties"). All references in this Agreement to a ?Party? or ?the Parties?l shall referOHlYIche Parties to this Agreement. A. On February 25, 2011, Plaintiff filed a complaint against Defendant in federal district court (Case No. EDCV 1,1491 (?Main 3:150:13, alleging oiaims under the Eighth Amendment for a back?ushing problem, and denial of cleaning supplies, a: the Southwest Detention Center and. Robert Presley Detention Center B. BnMay 5, 2014, Plaintiff ?led a civil ease against. Defendant in the Seperior Court of California, County of Riverside (Case No. RIC1404590) (?_?Rolated Action?), alleging violations of state and, federal rights for the aforementioned problems of baek?u?hing and denial of cleaning at SWDC and RPDC. C. On July 29, 2014, Plaintiff?s current counsel, Ketten Muchin Rosenman LLP, ?led a Notioe of Appearance in ihe district pourt ease, Pleiotiff had preyiomly litigatetlthe district a .- I NOW. THEREFORE, for good and valuable. consideration as eel: forth herein, the Parties to this Agneement, incorporating the Recitals 3e.t_..forlh above, hemby game as. follows: 1. PAYMENT BY DEFENDANT. Twenty-one (21) days from the Defendant's receipt of Plaintiff?s Wu9 form, Defendant shall deliver to Plaintiff?s counsel, Katie-n .Muehin Rosenman LLP, 2029 Ceni?ury Park East, Suite 2600, Los Angeles, California 9.0067, a check in the sum of TWENTY FIVE THOUSAND . payable to ?Thomas Bodnar" (the?Settlgitgent Raymeut"), 7 2. OF THE MAIN AND RELATED ACTIONS. Upon deliyery and deposit of the Se?lemotzt Payment, tho Pasties will canoe to be dismissed theMain Action and the 3. AGREEMENT NOT TO PURSUE SIMILAR CLAIMS BY PLAINTIFF. Plaintiff agrees [he will not ?le any future claim in any jurisdiction regarding any toilet back?ushing Problem and denial of gleaming supplies at SWDC or RPDC which allegedly oecuxged pyloric .llbetlato execution of this Agreement. If Plaintiff breaches this {portion of the agreement: Wombat! -il;?f?;1?e19 ate 52011919583? 1' . . 3 LEASE BY TIFF. Except for the obligations created by and. described in this Agreement, Plaintiff limitehy releases and . forever discharges Defendant and the Defendantls directors, attorneys, insurers, and employee-s from any and all claims, debts, Iiehilities, demands, obligations, QKWIISQS: mew-mics.Judemeeie $9121?? asaz-emeeou and causes of action of every nature. chareeter and descriptien, whether known er .tl?kll?WR, assented or unassened, .?xedor contingent, which Plaintiff has, 11.351.13.15. or may have had against Defendant liom. the beginning of timefto thedete of this Agreement that arise out 01" or relate to the claims and facts alleged in the Main or Related?ctions. Plaintiff further acknowledges that this Release bars andprovides an af?nnative defense against any andell petential state orlfederal claims arising out of or relating to the facts alleged in the. Main er?Releted Actions, whether pursuant to statute or common law, which have been or could have been brought, regardless of whether Plainti?f disqoyetfs edditienal facts or legal theories after the execution of this Release. 5. LAW. This Agreement shall be governed. by and interpreted, construed and energize. the laws cfthe State efCaliforniee - 6' Plaintiff-ack?m?il?dg?s that nerepreseetation has been made by the Defendant as to in?? appropriate 1?13"- Wamm ?any payments made. to Plaintiff or his astorneys, pursuant to this Release. . .. 7. AND ASSIGNS. This Agreement and the terms, covenants, conditions, provisions, obligations, undertakings, rights aed bene?ts hereto shall inure to the bene?t of the (Earths, and their respective agents, heirs, executors, administrators, representatives, empleyees, successors andysigng I. i 8? . . . DIEIQAT ON. Ne Waiver or modi?cation of the terms of this Agreement shall be binding unless made. in writing and signed by an Pg?ies' 11153 Agreement may in writing Sign? big-the:- parties. .. . . . .9. REPRESENT .. 1? .. . a. The Parties represent. that they have each read this Agreement and each is fully aware ofand understands all of its terms and legal consequences. b. The Parties represent that. they have consulted with, and have received advice from, independent legal counsel in eenneeticn with their. review and execution of this Agreement had the oppettuniy mid decling to do so. 0. The Parties have not relied on. any representations, promises cregreements other than these expressly setfceh inthis Agreement. . d. The Parties represent that they have the euthetity te enter into this Agreement, and hays: the epnseet pf.thin to enter into this Agreement. 10. Em;ng QGREEMENT. This Agreement eonslitutee the entire agreement made by and between the Partiesperteining to the settlement-of their disputes and fully supersedes any and all Prior er _.und.exstandings, .representatiees, and agteemeets made by the Parties .herete or their representatives pertaining to same. The Parties have .1101 relied on any facts, statements, 9.17 the failtire by enyperty to make stgtementser disclose facts, in entering into this Agreement. No. eminsiq 9r parol evidenee meme; may be in 3 anyiudicialmsedine inelvinethewmc?oe 9r eemwe . 4s4z.997e.eem.z 2 BINDING ON SUCCES-SORS. This Agreement shall inure to the bene?iof, and shaii be binding upon, each of the Parties hereto and, their 12. in the event any part of this Agreement is deemed unenforceabic, the will shall survive13. CQUNTBEPA RTS. This Agreement may he cxccutcd and delivered in separate counterparts, t:th of Which, when so exmum? and dgliyergd, shall be an original, but suph counterparts constitute but our; amt! thesauic instrument. and agreement. Facsimile signatures shall be and shallhave the 5am effect. asoriginal signaturcs. IN WITNESS WHEREOF. the Parties have. entered. DATED: 2 ?(it 2014 THOMAS BODNAR. . By: Thomas Bodnar DATED: 20.14 COUNTY OF RIVERSIDE By: Its: 4342-9976-8501; 3 11. BlquG QN SQCCESSORS. This Agreement shall inmate ?113 bene?t of, and shail be binding 13901}; $991?! 9f .ghcir macaw-13. - 12. ITY. In the event any part of. this Agreement is deemed unenforceable, the will he; swarm! and ?m?maining provisions__. shall survive. - "s -. - - 13. This Agreement may be .cxecuied and delivered in separate counterparts, each of Which, when so executed and delivered, shall an original, but such counterparts together shall constitute but (me and the same instazment and agresment. Facsimile signatures shall. be effective and aha]! have the same fox-ca. and. c?ect as ogigmal signatures. IN WEREOF, the Partics have gamma into Agreement: DATED: 2014 BODNAR. By: DATED: 0 C179 BEYAEOM COUNTY OF By: Its: aW-ns mum: 48423976413011. :3 APPROVED AS TO QRM: Date: /z?sms LP .. Stephanie Tanada Counsel for County 9f Riverside KATTEN CHIN ROSENMAN LLP Date! {3/0904 By: Stevcc hm - Gregory Konnara Soyoung Jung Counsel for Thomas Bodnar 4842-9976-3501: 4