WILLITS, et al v. CITY OF LOS ANGELES - Settlement Agreement and Release of Claims

4. Purpose of Settlement

To avoid the cost, expense, and uncertainty of protracted litigation and preclude any similar lawsuits or challenges during the Compliance Period, the City and Plaintiffs agree to enter into this Settlement Agreement and that it shall be binding upon the City, Plaintiffs, and all members of the Settlement Class, shall extinguish all Released Claims and shall constitute the final and complete resolution of all issues addressed herein. The Parties agree that this Section and other terms of this Settlement Agreement are intended to and shall prevent relitigation of any issues settled herein and that none of the Parties shall take the position that the doctrines of res judicata and collateral estoppel do not apply to the Parties or the Settlement Class.