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breach of contract, breach of covenant of good faith and fair <br />dealing, fraud and deceit, defamation, violation of Labor Code <br />Section 1050, and violation of federal and state civil rights; and <br />WHEREAS, HERRON and COLTON, without either of them conceding <br />the correctness of the position of any other, in order to avoid the <br />costs, uncertainty, and vexation of further legal proceedings, have <br />agreed to settle all disputes between them, fully, finally, and <br />completely; and <br />NOW, THEREFORE, in consideration of the mutual promises <br />contained herein, it is agreed as follows: <br />1. COLTON shall cause to be paid to HERRON in exchange for <br />HERRON's General Release and the promises made by HERRON contained <br />in this Agreement the sum of $47,500 (Forty-seven Thousand Five <br />Hundred Dollars) in settlement of claims for alleged physical and <br />emotional injuries arising out of and in the course of his <br />employment with COLTON. This payment will be paid by check made <br />payable to KENNETH E. HERRON and his attorney, JAMES P. STONEMAN <br />I I , and will be forwarded to HERRON' s counsel on or before July 12, <br />1994. <br />2. HERRON hereby expressly releases and waives, and <br />absolutely and forever discharges COLTON and interrelated entities, <br />officers, directors, agents, representatives, employees, former <br />employees, present or past City Council members, present or past <br />Civil Service Commission members, predecessors, successors, and <br />assigns (collectively the "COLTON RELEASEES"), and any and all of <br />them, from any and all claims, liabilities, demands, debts, <br />2 of 9 <br />