Laserfiche WebLink
ATTY/AGR/SETTLEMENTS/2025/ECHEMA/SETTLEMENT AGREEMENT & MUTUAL RELEASE – ECHEMA <br />REV: 10-10-25 MI <br />Page 1 of 7 <br />SETTLEMENT AGREEMENT AND MUTUAL RELEASE <br /> <br />This Settlement Agreement and Mutual Release (“Agreement”) is entered into by and <br />between Joseph Echema (“Plaintiff”) and the City of Redwood City (“City”) (collectively “the <br />Parties”). It is effective as of the latest date of a Party’s signature below (“Effective Date”). <br /> <br />RECITALS <br /> <br />A. Plaintiff was employed in City’s Fire Department from 2012 until retirement in <br />2024. <br /> <br />B. In July 2020, Plaintiff filed a Complaint against the City in Alameda County <br />Superior Court, which was transferred to San Mateo County Superior Court, case number <br />21CIV01571 (the “Action”). <br /> <br />C. City denies the validity of any claims asserted by Plaintiff. <br /> <br />D. Plaintiff and the City desire to resolve, fully and finally, any and all disputes <br />between them pertaining to Plaintiff’s employment. <br /> <br />Now, therefore, the Parties agree as follows: <br /> <br />AGREEMENTS <br /> <br />1. No Admission of Liability. This Agreement and compliance with it may not be <br />construed as an admission by the City of any liability whatsoever or as an admission by City of <br />any wrongdoing under any common law, statute or contractual obligation. City specifically <br />disclaims any wrongdoing and disclaims any liability to Plaintiff for any violation of law, <br />regulation, duty, or contract, including but not limited to the facts alleged relating to the Action, <br />or otherwise. Plaintiff also agrees not to represent or imply to anyone that the provision of <br />consideration under this Agreement is in any way an admission by City that any of his rights were <br />violated. <br /> <br />2. Dismissal of Action, Covenant Not to Sue; Return of Materials. <br /> <br />(a) Plaintiff will dismiss with prejudice the Action by filing a dismissal of the entire <br />Action as against all defendants, with prejudice, within ten business (10) days of receiving the <br />payment described below , and a file-endorsed copy of the dismissal with prejudice will be served <br />on City’s legal counsel. <br /> <br />(b) Plaintiff covenants that he will not institute any type of complaint, action, or claim <br />in any forum based on any matters arising out of his employment with City or the subject matter <br />of the Action. <br /> <br />(c) The Parties and counsel agree that, within thirty (30) calendar days of the filing of <br />the dismissal above, all materials subject to the parties’ protective order shall either (i) be returned