Johnson, Joseph L., et al. CASE NO.

Plaintiff(s), REF. No.1 100080931

vs. STIPULATION FOR SETTLEMENT
C.C.P. 664.6
City of Vallejo, et al. 

Defendant(s) 



 

This case having come before Hon. Scott Snowden (Ret.) for mediation at the offices of JAMS,
and the parties having conferred, it is hereby stipulated that this matter is deemed settled pursuant to the

following terms and conditionsshall pay to plaintiff(s)
as :3 Lect?ke and to Mather-Alien attorneys?
(qj'nC?

Juab?l 

Bewlw? Vii?rug (gnaw the total sum of 2. i can an in full settlement

and compromise of this action and in release and discharge of any and all claims and causes of action
made in this action, and in release and discharge of any and all claims and causes of action arising out of
the events or incidents referred to in the pleadings in this action.

2. Plaintiff(s) agree to accept said sum in full settlement and compromise of the action and agree
that such payment shall fully and forever discharge and release all claims and causes of action, whether
now known or now unknown, which plaintiff(s) has against any and all of the defendants in that action
arising out of the incident.

This settlement includes an express waiver of Civil Code 1542, which states:

general release does not extend to claims which the creditor does
not know or suspect to exist in his or'her favor at the time of

executing the release, which if known by him or her must have
materially affected his settlement with the debtor."

3. Plaintiff(s) further agree to sign, acknowledge and deliver to defendants a standard form of a

Release of all such claims and causes of action and to sign and deliver to defendants a standard form of
Dismissal with Prejudice of the action.

4. Plaintiff(s) shall protect, defend and indemnify the defendants in said action, (and
his/her/their liability insurance carrier(s)) against any and all liens, subrogation claims and other rights
that may be asserted by any person against the amount paid in settlement of the action or against any
recovery by the plaintif?s) in the action.

5. Counsel for each of the parties to this agreement represents that he/she has fully explained to
his/her client(s) the legal effect of this agreement and of the Release and Dismissal with Prejudice
7 provided for herein and that the settlement and compromise stated herein is ?nal and conclusive
forthwith, and each attorney represents that his/her client(s) has freely consented to and authorized this
agreement.

6. Payment of the stated settlement amount shall be made by as soon as reasonably possible.

7. Unless otherwise stated herein, each party will bear its own attomeys' fees and court costs.

8. Other terms and conditions:

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9. Any provisions of Evidence Code 1115 - 1128 notwithstanding, this Stipulation is binding

and may be enforced by a motion under Code of Civil Procedure 664.6 or by any other procedure

permitted by law in the applicable state or federal court.

10. This Stipulation is admissible and subject to disclosure for purposes of enforcing this settlement
agreement pursuant to GOP 664.6, or any other procedure permitted by law, and the provisions of the
con?dentiality agreement signed by the parties relative to this mediation are waived with respect to this

Stipulation.

Date: lig?

Mark A. Jon .
Jones&Dye
Ci of 211%

Dustin B. Joseph

 

 

 

 

 

 

Sean G. Kenney

 

Joseph M. Kreins

 

Ms. Kristen Preston
Jones Dyer

 

City of Vallejo

 

Dustin B. Joseph

 

Sean G. Kenney

 

Joseph M. Kreins

 

Ms. Claudia Quintana
City of Vallejo, City Hall

 

City of Vallejo

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