‘SETTLEMENT AGREEMENT AND MUTUTAL RELBASE
‘This Settlement Agreement and Mutual Release (“Agreement is made and entered into
by and between Plaintiff Rebeees Gasca (“Gasca”) and the City of Reno (colletvely, “the
Parties"). In consideration forthe covenants, agreements, and releases set forth herein and
valuable consideration, it is agreed by and between Gasca and the City of Reno that this
‘Agreement resolves the Lawsuit (as defined below).
1, Payment and Approval by City Coun
In consideration for the release and terms set forth herein the City of Reno shall py the
sum of Two Hundred Fifty Thousand Dollars and No Cents ($250,000.00) (inclusive of fes and
coss) by check payable to “MeLetchie Law Group, PLLC Trust Account” (“MeLetchie Law”)
MeLetchie Law will provide an IRS Form W-9 to City's atoreys no later than five (S) business
days after the date this Agreament is fully executed
2 Release by Gasea:
Gasca on behalf of herself and all her dependents, heir, agents, executors, successors,
and asigns, does hereby release, waive, and discharge the City of Reno, Jason Soto, Kevin Boh,
‘Tom Robinson, Cury Lynch, and al of ther hers, successors, assigns, atoms, insurers,
employees, officer, agents, divisions, departments, and representatives (collectively, “Reno
Released Parties" of an from any and all actions, causes of action claims, demands, costs,
expenses, known or unknown, suspected oF unsuspected relating In any manner whatsoever to &
protest that took pace in Reno, Nevada on May 30, 2020 and al of those matters an claims
which were raised or could have been rised inthe 42 U.S.C.§ 1983 civil rights lawsuit pending
in the United States District Court for the District of Nevade as Case No. 3:22-cv-00238-MMD-
SD and entitled Rebecca Gasca, an individual, Plaimif vs. City of Reno, Nevada a Municipal
Corporation, et al. (he Lawsuit)
3. Release by the City of Reno:
‘The City of Reno on behalf of itself, its agents and employees (including but not limited
to the Reno Released Parties) hereby releases, waives, and discharges Plaintiff Rebecea Gasca
{rom al actions, causes of ation, claims, demands, costs, expenses, Known or unknown,
suspected or unsuspected, including but not limited to any claims for attorney fees andor costs
relating in any manner whatsoever tothe protest that took place in Reno, Nevada on May 30,
2020, and all of those matters and claims which were eased or could have been raised in the
Lawsuit or relate flings,
4. Released claims may not be fully known:
‘The undersigned expressly understand that all damages, injuries, and losses claimed by
‘the undersigned may not now be fully known, and may be ofa different type and nature than
‘now known or expected. Itis further understood that his Agreement includes any and allpurported claims for reef and causes of action based on allegations of physical or mental pain
and suffering.
‘5. Parties will not initiate any further action on released claims:
‘The Parties agree that they will ot, at anytime hereafter, commence, maintin, oF
prosecute any action, a law or otherwise, or assert any claim against any released party and/or
‘execute or enforce any judgment against any released party for damages, losses, o fr equitable
relief relating to the matters and claims herein released. However, nothing in this provision
‘prevents the Parties from seeking to enfore this Agreement
66. Consideration of policies and procedures and/or training
‘The City of Reno agrees to consider and engage in good faith discussions (including but
not limited to # meeting with the Chief of Police andior others withthe Reno Police Department
involved withthe formulation of polices and procedures and/or taining and the City Atomney's
Office) with Gasca and her attorey regarding potential changes to polices and procedures
andior police taining regarding use of force (including with espect to the nonlethal round
‘commonly called 4Omm Direct Impact OC used in the protest on May 30, 2020 and that Gasca
alleged inthe Lawsuit caused her injury) and other issues concerning policing of protests to
avoid the unnecessary use of force on protesters and others atending protests
artis have reviewed and intend to be lgally bound by Agreement:
Each of the Parties acknowledges and agrees that each of them has reviewed and
understands this Agreement, and each has had the opportunity to have this Agreement reviewed
by their respective attorneys. The undersigned, as individuals or representatives ofthe Parties,
further declare that this entre Agreement has been eateully read, that the contents hereof ae
fully known and understood, thatthe same is signed asa free and voluntary act of the
undersigned, and that itis an express intention ofthe undersigned to waive, release, and
discharge any and all claims or causes of aetion asset fort in Sections? and 3, and t be fully
and legally bound hereby.
1. Parties to bear their own fees and costs:
‘The Partis agree the shall ber thet own attorney's fees and costs in connection with
the Lawsuit, including this Agreement, andthe setlement makes no allocation for fees and costs.
9, Disputed claims and no admission oflisility
Itis expressly understood that ths setlement is a compromise of disputed claims, and
receipt ofthe consideration above is nat to be construed as an admission or acknowledgement of|
libilty or responsibility onthe prt ofthe Parties or any released party, al of whom expressly