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Walker, Bryana 2025-05-27 Release of All Claims CVPS-2302309RELEASE OF ALL CLAIMS This agreement is made by and between BRYANA WALKER (hereinafter called "Releasor") and the CITY OF LA QUINTA. Releasor, pursuant to Sections 1541 and 1542 of the California Civil Code, extinguishes her rights and claims against the CITY OF LA QUINTA, and the other Releasees described below as hereinafter enumerated. In consideration of $45,000.00 paid to Walter Clark Legal Group and Bryana Walker by or on behalf of the CITY OF LA QUINTA, Releasor agrees as follows: 1. Releasor, on behalf of herself, her heirs, agents, executors, administrators, and assigns, hereby fully releases and discharges the CITY OF LA QUINTA and its joint powers insurance authority, insurers, administrators, affiliates, assigns, employees, agents, officers, directors, partners, subsidiaries, parent companies, themselves and their successors (hereinafter collectively "Releasees") from all rights, claims, and actions which the Releasor and her above -mentioned successors now have or may, after the signing of this agreement, have against Releasees arising out of the Incident, as more fully described in Releasor's Complaint, Case No. CVPS2302309, pending in the California Superior Court for the County of Riverside. 2. This agreement releases all claims for injuries, damages, or losses to Releasor's person and property, real or personal, whether known, unknown, foreseen, unforeseen, patent or latent, which Releasor may have against Releasees. Releasor understands and acknowledges the significance and consequence of a specific waiver of the protection of California Civil Code Section 1542, and hereby assumes full responsibility for any injuries, damages, or losses that she may incur from the above -mentioned Incident. Releasor specifically waives the protection of Section 1542 of the California Civil Code, which provides that: A general release does not extend to claims that the creditor or releasing party does not know 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. 3. This release and settlement includes any and all claims and liens for medical services, government benefits, legal services, or liens of any other kind whatsoever, whether actual or asserted, present or prospective, any claims, causes of action, or rights to attorney fees, interest, and costs incurred, whether actual or asserted, present or prospective, as against Releasees. Releasor represents that she has not received, and does not expect to receive, Medicare benefits in connection with any injury that she sustained as a result of the Incident, as more fully described in Releasor's Complaint, Case No. CVPS2302309, pending in the California Superior Court for the County of Riverside. Releasors waive any private cause of action that Releasor may now or at any later time have against Releasees pursuant to 42 U.S.C. § 1395y in relation to the Incident, as more fully described in Releasor's Complaint, Case No. CVPS2302309, pending in the California Superior Court for the County of Riverside. Releasor further agrees for herself, her heirs, agents, executors, administrators, and assigns to fully and expressly indemnify, save and hold harmless and defend Releasees for and against all claims, demands, causes of action, damages, costs, and losses, and liabilities arising out of any lien or claim described herein. Releasor acknowledges her right to seek waiver, compromise, or a reduction of claims, demands, causes of action, damages, costs and losses, and liabilities arising out of any lien or claim described herein. In the event of Page 1 of 4 BRYANA WALKER v. CITY OF LA QUINTA Riverside County Superior Court Case No. CVPS2302309 any claim, lien, demand, cause of action described herein, Releasor agrees to cooperate with Releasees to comply with reasonable requests for information or documents, a copy of any settlement agreement, waiver, or other document evidencing resolution. 4. Releasor agrees to dismiss Riverside County Superior Court Case No. CVPS2302309 in its entirety with prejudice within seven days after Releasor's counsel has received a $45,000 settlement draft payable to Walter Clark Legal Group and Bryana Walker. Releasor agrees that, if Case No. CVPS2302309 is not so dismissed, she will be liable for reasonable attorney fees and costs incurred on behalf of the CITY OF LA QUINTA required to enforce this agreement. In the alternative, Releasor may provide counsel for the CITY OF LA QUINTA with an executed request for dismissal of her entire case along with this signed agreement, and counsel for the CITY OF LA QUINTA will file the request for dismissal but only after confirming that Releasor's counsel has received the settlement draft. 5. Furthermore, Releasor agrees that the monies paid to Releasor in consideration of this agreement are for reimbursement of medical expenses, lost wages, out-of-pocket expenses, and disability, as well as complaints of pain and suffering, which resulted from the events that form the basis of Case No. CVPS2302309, pending in the California Superior Court for the County of Riverside. 6. Releasor understands and agrees that, if any fact with respect to which the release is executed is discovered hereafter to be other than or different from the facts now believed to be true, Releasor expressly accepts and assumes the risk of such possible differences and agrees that this release shall remain effective notwithstanding such differences. 7. Releasor shall keep the terms and amount of this settlement, as well as the parties to the agreement, confidential. Releasor will not disclose any information concerning this Release to any person, party or entity other than Releasor's attorneys, her accountants, tax advisers, family members, or others with a need to know based on representing Releasor's legal or financial interests. Notwithstanding the above, it is expressly agreed that Releasor may state in response to inquiries that the litigation between the parties is resolved. 8. It is understood and agreed that this settlement is the compromise of a doubtful and disputed claim and that payment of said money is not to be construed as an admission of liability on the part of Releasees, by whom liability is expressly denied. 9. If any provision of this agreement is determined to be invalid or unenforceable, the remainder shall remain in full force and effect and shall not be affected thereby unless the invalid provision(s) goes to the heart of the agreement and destroys its purpose and intent. 10. No inference, assumption, or presumption shall be drawn from the fact that a party or its attorney prepared and/or drafted this agreement. It shall be conclusively presumed that all parties participated equally in the preparation and/or drafting of this agreement. 11. Any dispute arising out of or related to this agreement shall be resolved in the California Superior Court for the County of Riverside, which shall retain jurisdiction to enforce the parties' settlement pursuant to Code of Civil Procedure §664.6. Page 2 of 4 BRYANA WALKER v. CITY OF LA QUINTA Riverside County Superior Court Case No. CVPS2302309 12. This agreement is freely and voluntarily executed by BRYANA WALKER, who hereby declares and represents that, in making this release and agreement, it is understood and agreed that she relies wholly upon Releasor's counsel and agents and her own judgment, and that she has not been influenced to any extent whatever in making this release by any representations or statements made by persons, firms, or corporations who are hereby released, or by any person or persons representing them or by any healthcare provider employed by them. 13. Releasor hereby represents that at the time she signs this agreement, she has not been hospitalized in a medical facility nor admitted to a medical facility within the past 15 days. Releasor further represents that this agreement is not executed under duress. 14. In executing this agreement, Releasor acknowledges she has had the opportunity to seek the advice and counsel of an attorney prior to execution of this agreement and that she has executed this agreement after independent investigation and without fraud, duress, or undue influence. 15. This release contains the entire agreement between the parties hereto, and the terms of this release are contractual and not a mere recital. 16. A signed facsimile copy or electronic copy of this agreement shall be deemed an original. I have read the foregoing agreement and know the contents thereof and sign the same as a free act. CAUTION: READ BEFORE SIGNING. DATED May 27, 2025 , 2025 &yam Wale" BRYANA WALKER Page 3 of 4 BRYANA WALKER v. CITY OF LA QUINTA Riverside County Superior Court Case No. CVPS2302309 ADDENDUM TO RELEASE OF ALL CLAIMS I, BRYANA WALKER, represent and warrant that I have not received Medicare benefits and that there is no Lien for Conditional Payments being asserted by Medicare for any treatment associated with the Incident, as more fully described in Releasor's Complaint, Case No. CVPS2302309, pending in the California Superior Court for the County of Riverside. I declare under the penalty of the laws of the State of California that the foregoing is true and correct. Executed this day of May 27, 2025 , 2025, in , California. ?3 wta Water. BRYANA WALKER Page 4 of 4 BRYANA WALKER v. CITY OF LA QUINTA Riverside County Superior Court Case No. CVPS2302309 docubee Signature Process Reference: 7337a2a3-593b-459e-8e72-0976414alec4 PARTICIPANT DETAILS Process started 27-May-2025 7:48 PM EDT brywalk17@gmail.com brywalk17@gmail.com IP Address: 24.30.135.202 Document viewed 27-May-2025 11:35 PM EDT Reference ID: bcb808e3-3100-4e6e-a116-8074f81b1455 brywalk17@gmail.com brywalkl7@gmail.com IP Address: 24.30.135.202 Document accepted & signed 27-May-2025 11:36 PM EDT Reference ID:bcb808e3-3100-4e6e-a116-8074f81b1455 Document has been completed 27-May-2025 11:36 PM EDT