1 David Yakobson
From: Brian O'Neil <[email protected]>
Sent: Tuesday, May 28, 2024 3:53 PM
To: councilmtgitems; Phil Brock; Gleam Davis; Oscar de la Torre; Lana Negrete; Christine Parra; Caroline Torosis; Jesse Zwick; David White
Cc: PNA; Brian ONeil
Subject: City Council May 28 Agenda Item 4A - ENA with Revitalization Partners Group
EXTERNAL
To: Mayor Brock and Council Members
From: Board of the Pico Neighborhood Association
Date: May 28, 2024
RE: Item 4A on the May 28 Council Agenda
The PNA Board wholeheartedly supports and endorses the letter below sent to you from Save the Civic calling on the City “to enter into an ENA with Revitalization Partners Group (RPG) to seismically upgrade, restore, program, and operate our Landmark Civic Auditorium as a performing arts and cultural center.“ Highest Regards,
PNA Board
Save the Civic Letter:
Dear Council Member,
On May 28, 2024 you have an opportunity to enter into an ENA with Revitalization Partners Group (RPG) to seismically upgrade, restore, program, and operate our Landmark Civic Auditorium as a performing arts and cultural center. Save the Civic urges you to act without delay.
Save the Civic (STC) was formed after an outpouring of resident concern that the Cityowned Civic Auditorium had been declared surplus land, enabling its possible sale.
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2 Save the Civic had three guiding principles:
1) Public land should not be privatized; neither the Civic nor the land around it should be sold to a private entity.
2) This landmark building should be preserved, not demolished. 3) City-owned performing arts centers are rare and important; the Civic should not be repurposed but restored for its original purpose as a performing arts and cultural center.
STC was also aware that the City had no funds to restore the Civic, nor did we think it wise for taxpayers to be asked to pay for such a project. The Civic would have to be financially self-sufficient, and optimally it should create a future revenue stream for the City.
Now you have an exceptional opportunity to enter into an ENA with RPG, a group that checks all of these boxes.
This opportunity comes to you after hard work from residents to make it happen. It is also a chance for the City and residents to work together to create something wonderful and exciting - - a chance to restore a vacant and respected landmark and turn it into a worldclass performing arts and cultural center and an economic generator.
From where we sit, it’s a win-win.
We hope you will vote to enter into an ENA with the Revitalization Partners Group so we can keep this exciting prospect for Santa Monica moving forward.
Thank you from Save the Civic,
Bea Nemlaha
Diana Gordon
Lori Nafshun
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3 Victor Fresco
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1 David Yakobson
From: Chris Harding <[email protected]>
Sent: Tuesday, May 28, 2024 11:22 AM
To: councilmtgitems; Phil Brock; Lana Negrete; Gleam Davis; Christine Parra; Caroline Torosis; Jesse Zwick; Oscar de la Torre
Cc: David White; Douglas Sloan; Susan Cola; Joe Pertel
Subject: The CVRA Case and Councilmember Oscar de la Torre Conflict of Interest Attachments: Ltr to CC 2024-05-28.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
EXTERNAL
Dear Councilmembers,
Please see the attached letter from Joe Pertel and me with respect to the CVRA case and Oscar de la Torre’s conflict of interest.
Sincerely,
Chris Harding
Christopher M. Harding | Attorney at Law
1250 Sixth Street, Suite 200 | Santa Monica, CA 90401
O: (310) 451-2968 | [email protected]
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1 CHRISTOPHER M. HARDING
1250 SIXTH STREET, SUITE 200
SANTA MONICA, CALIFORNIA 90401
E-MAIL: [email protected]
JOSEPH A. PERTEL
2801 Ocean Park Boulevard
SANTA MONICA, CALIFORNIA 90405
E-MAIL: [email protected]
May 28, 2024
VIA E-MAIL
Santa Monica City Council
1685 Main Street, Room 209
Santa Monica, CA 90401
Re: The CVRA Case and Councilmember Oscar de la Torre’s Conflict of Interest
Hearing Date: May 28, 2024
Agenda Item No. 4-A
Dear Councilmembers:
We are writing (again) with respect to the CVRA case.
In our most recent letter (dated May 10, 2024), we explained why it would be unlawful and imprudent for the City Council to “settle” (i.e., concede) this case. Our legal argument is simple and compelling:
The Santa Monica City Charter, in section 600, establishes at-large elections for City Council.
Article XI, section 3 of the California Constitution provides that amendments to a City Charter require voter approval.
This letter focuses on Councilmember Oscar de la Torre’s conflict of interest in voting as a councilmember given his marital relationship with plaintiff Maria Loya and his attorney-client relationship with plaintiffs’ attorney Kevin Shenkman. At your May 14th hearing, Councilmember de la Torre misrepresented the conflict of interest issue, stating:
“And [I’m] back in closed session, and the reason why is because the judge said I can return to closed session. And that’s why I’m back in closed session and the judge did declare that there was no conflict of interest. That I had no conflict of interest. And that’s why I’m allowed to be back in Item 4-A
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2 closed session. So I just wanted to clarify that for the record.
Thank you very much.”1
This statement is false. Councilmember de la Torre is in closed session on the CVRA case because the City entered into a settlement agreement that provides de la Torre may decide for himself whether or not he has a conflict of interest. (A copy of the settlement agreement, which CEPS believes was ill-advised, is attached.) The judge in the de la Torre lawsuit never decided he lacks a conflict of interest. Nor did the judge order that the City Council allow de la Torre in City Council discussions or voting on the CVRA case.
To the contrary, the judge in question (Judge Fruin) rejected de la Torre’s request for a determination that he lacks a conflict of interest. In denying de la Torre’s summary judgment motion, Judge Fruin stated:
“Plaintiffs support their motion only with declarations from De la Torre and Shenkman (not counting the Trivino-Perez
declaration to provide the Court with a copy of its own prior ruling). The Shenkman declaration does not address what plaintiffs knew would be a main issue for the City, e.g. its contention that Shenkman is a de facto attorney for De La Torre. The De La Torre declaration does not address the elephant in the room: should he participate in the City’s decisions as to the claims of the CVRA attorneys for $22 million in attorneys’ fees (inflated by the use of 2.3
multiplier).
A movant for summary judgment cannot ignore obvious
issues and expect that the Court too will ignore those
questions and grant summary judgment.”2
Thus, Councilmember de la Torre’s claims (made repeatedly including at your May 14th hearing) that the court (i) decided he has no conflict of interest and (ii) ordered that he be allowed to participate in City Council deliberations and voting are false.
Because Councilmember de la Torre persists in making these false claims, we ask that the City Attorney state as a matter of public record that there is no court determination as to whether Councilmember de la Torre has a conflict of interest in the CVRA case, nor is there a court order that de la Torre be allowed to participate in City Council deliberations and voting.
Our clients continue to believe that Councilmember de la Torre has a conflict of interest (both financial and common law) that legally and ethically prohibits him from participating in the City Council’s deliberations and voting on the CVRA case. We explained this at length in our March 20, 2023 letter to you. Councilmember de la Torre 1 See attached transcript of Natalya Zernitskaya’s testimony and Councilmember de la Torre’s response.
2 Judge Fruin’s ruling on the de la Torre and City summary judgment motions at p. 18 (copy attached).
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May 14, 2023 City Council Partial Transcript
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Santa Monica City Council Meeting
May 14, 2024
1:46:30
Zernitskaya Good evening. I’m testifying on Item 4D, the closed session item on the CVRA case. The case has been remanded back to the Superior Court for a new trial, and the City should continue to stay the course and let this matter be adjudicated in the appropriate court of law. Staying the course is in the best interest of Santa Monica voters and it is the most fiscally responsible choice. The Supreme Court issued a ruling clarifying how a plaintiff would need to prove vote dilution under the CVRA and clarify that both racially polarized voting and vote dilution must be proven to demonstrate a violation of CVRA. The Supreme Court and the Court of Appeal on two occasions did not rule in favor of the plaintiffs and it appears that the City is on the verge of winning this case as the plaintiffs would not be able to prove either racially polarized voting nor vote dilution under the CVRA. Further, I urge Councilmember de la Torre to recuse himself from Item 4D in future closed session agenda items regarding this lawsuit due to an undeniable conflict of interest. Prior to being elected to the City Council in 2020, Councilmember de la Torre served as chair of the Pico Neighborhood Association, a coplaintiff in the CVRA lawsuit filed against the City. The other coplaintiff in the lawsuit is the councilmember spouse. In January 2021, the City Council voted to disqualify the then newly elected councilmember from participating in or attempting to influence discussions or decisions relating to this litigation due to a finding of the common law conflict of interest. In March 2021, the councilmember filed a lawsuit against the City for declaratory relief, injunctive relief, alleging a violation of the Brown Act. In June 2022, there was a settlement between the City and the councilmember on the conflict of interest case. There was no ultimate final ruling by the judge, and in fact, the judge in the conflict-of-interest case denied issuing summary judgment to both the councilmember and the City. Thank you.
Mayor Thank you, Natalya.
de la Torre Mayor, I’d like to point a privilege. The last speaker said that – made allegations that I have a conflict of interest. She is very accurate that there was a lawsuit because the City Council voted to disqualify me from any discussions in closed session regarding the voting rights case. And back in closed session, and the reason why is because the judge said I can return to closed session. And that’s why I’m back in closed session and the judge did declare that there was no conflict of interest. That I had no conflict of interest. And that’s why I’m allowed to be back in closed session. So I just wanted to clarify that for the record. Thank you very much.
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Settlement Agreement
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CM-200
ATTORNEY OR PARTY WITHOUT ATTORNEY {Name, State Bar number, are address) FOR COURT USE-ONLY :
Wilfredo Trivino-Perez, SBN 219345
Trivino Perez & Associates
40940 Wilshire: Bivd., 16th Floor
Los ‘Angeles, CA 90024
TELEPHONE NO 210-443-4257 FAX NO. (Optional: :
| E4WALL ADDRESS (Optional): [email protected]
ATTORNEY FOR (Wane): Plaintiffs Osear de la Torre and Elias Serna SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles - Central District STREET ADDRESS: 111-N. Hil Street (
MAILING ADORESS 111 .N. Hil St
erty AND ZIP CODE: Los Angeles, 99012
RANCH NAME: Stanley Mosk Courthouse
| PLAINTIFF/PETITIONER: Oscar de la Torre and Ellas Serna DEFENDANT/RESPONDENT: City:of Santa Monica |
| CASE NUMBER:
21ISTCVO8597
NOTICE OF SETTLEMENT OF ENTIRE CASE — JUDGE: Richard:L..Fruin } DEPT.. 16
NOTICE TO PLAINTIFF OR OTHER PARTY SEEKING RELIEF
You must file a request for dismissal of the entire case within 45 days after the date of the settlement ifthe settlement is unconditional. You musttile a dismissal of the antire case within 45 days after the date specified in item 1b below if the settlement is conditional. Unless you file 4 distnissal-within the required time or have shown good cause before the time for. dismissal has expited why the case should not be dismissed, the court will dismiss: the entire case.
To the court, all parties, and any arbitrator or other court-connected ADR neutral involved in this case:
1. This entire case has been settled. The settlement is:
a. [#7] Unconditional. A request for dismissal will be filed within 45 days after the date of the settlement.
Date of settlement: 07-18-2022
b. [7] Conditional. The settlement agreement conditions dismissal of this matter on the satisfactory completion of specified terms that are not to be performed within 45 days of the date of the settlement. A request for dismissal will be filed no later than (date):
2. Date initial pleading filed: 03-04-2021
3. Next scheduled hearing or conference:
a. Purpose: Final Status Conference
b. [¥] (1) Date: 96/os2022
(2) Time: 8:30AM
7 (3) Department: 15
4. Trial date:
a. [x] No trial date sel.
b. [7] (1) Date: 08/15/2022
(2) Time: -&30AM
(3) Department: 15
| declare under penalty of perjury under the laws of the State of California that the foregoing is true and: correct. : Date: July 20,2022 me r
: Wilfredo. Trivino-Perez ME Pha AND djeat,
(TYPE OR PRINT NAME OF * ATTORNEY: PARTY WITHGUT ATTORNEY) (SGNATURE) Page-t.of 2
{ F Adopted for Mandatory U} : - Cal. Rules of Court, rule3.1385 dielel ameitor Celferia NOTICE OF SETTLEMENT OF ENTIRE CASE ameaese vey cours-cB 9 CM-200 (Rev. January 41,2007]
Electronically FILED by Superior Court of California, County of Los Angeles on 07/20/2022 09:13 AM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Thomas,Deputy Clerk Item 4-A
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DocuSign Envelope ID: 7F3DB7F4-2320-4261-96EF-8079DD0C5459 This Settlement Agreement (Agreement) is entered into and effective as of July 18, 2022, by and among Plaintiffs Oscar de la Torre, an individual and Councilmember ofthe City of Santa Monica (‘de la Torre"), and Elias Serna, an individual (‘Serna’) (collectively “Plaintiffs”); and Defendant the City of Santa Monica, a municipal corporation and a California charter city duly organized under the laws of the State of California, acting through its City Council (°City” or “City Council”) (all collectively the “Parties”).
RECITALS
A. Plaintiff Oscar de la Torre is a Councilmember for the City of Santa Monica, California, and has been since December 2020. Serna is an individual resident of the City of Santa Monica.
B. A dispute arose beiween the City Council and dela Torre as to whether dela Torre had a disqualifying conflict of interest that precluded his involvement in City Council - decisions and discussions concerning the litigation captioned Pico Neighborhood Association, et al. v. City of Santa Monica, Los Angeles Superior Court, Case No. BC 616804, Second District Court of Appeal, Case No. B295935, California Supreme Court, Case No. S263972 (Pico case).
Cc. A majority of the City Council voted to exclude de la Torre from participation in the Pice case.
D. Thereafter, Plaintiffs filed suit in the case captioned Oscar de /a Torre, et al. v. City of Santa Monica, Los Angeles Superior Court, Case No.. 21STCVO08597 (Conflict case), claiming a conflict of interest does not exist and challenging the Council decision to exclude dela Torre.
E. Now, following discovery and the Parties having filed motions for summary judgment, which were all denied, the Parties have determined it is in the Parties’ best interests and the public interest to resolve this matter.
F. The Parties agree this Agreement is the compromise of disputed claims and this Agreement may not be construed as an admission of liability or wrong doing on the part of. any Panty or individual.
G. The City Council and each of its members intend this Agreement to bind the City City Council, and each City Councilmember individually.
NOW, THEREFORE, in consideration of the foregoing Recitals and the mutual covenants set forth below, and further good and valuabie consideration, the sufficiency of which is hereby acknowledged, the Parties do hereby agree as follows:
1. The above Recitals are incorporated into this Agreement.
2. Settlement Terms. The Parties agree to the following terms to settle and resolve the Conflict case:
a. Upon the full execution of this Agreement, the Parties shall joinily file a stipulation of dismissal of the Confiict Case with the Los Angeles Superior Court.
The stipulation of dismissal shall provide for the dismissal with prejudice of the Conflict Case, shall attach this Agreement fully executed by the Parties, provide for the Court to retain jurisdiction pursuant to Code of Civil Procedure section 664.6 to enforce this Agreement until full performance of the terms of this Agreement, which shall be no sooner than the ultimate conclusion of the Pico case, and include a@ proposed order fer the Gourt’s assent to the stipwation, Item 4-A
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DocuSign Envelope ID: 7F3DB7F4-2320-4261-96EF-8D79DD0C545S b. The City Council hereby withdraws and vacates its decision to exclude Councilmember de ia Torre from closed sessions or any other participation in the Pico case.
c. City shall not exclude, or seek to involuntarily exclude, Councilmember de la Torre from any discussions, decisions or other participation in ihe Pico case.
Rather, the Parties agree that, with respect to the Pico case, the decision to recuse on account of any potential conflict of interest shall be left te each Councilmember, who may seek advice from the City Attorney if there is any question of a potential conflict.
d. The Parties shall issue a neutral agreed upon statement in the form attached hereto as Exhibit A, with no other public or media discussion by Councilmembers or City of the Conflict case or this Agreement, other than to refer to the neutral statement. Any questions as to application ofthis provision shall be discussed between Plaintiffs’ counsel and the City Attorney. a. No Councilmember will disclose confidential information irom closed session discussions ar any City attorney-client privileged communication regarding the Pico case without the City Attorney present, except as required by law, and no Councilmember shail assert any privilege in response to any question as to whether this will have occurred in the future. If there is any question or concern about what can be disclosed, the City Attorney shall be consulted before any such disclosure. The remedy for Councilmember violations of this provision shail be any remedy under the law, and the Parties expressly reserve the right to argue that any Councilmember who unlawtully discloses confidential information from closed session discussions should be recused fram further participation in the Pico case.
Counsel for Councitmember de ja Torre consent to his discussing this matter with the City Attorney, other than prior attorney client privileged communications, following the effective date of this Agreement.
f. The City shall pay $92,500 to Mr. Trivino-Perez for reimbursement for fees and costs in the Conflict case; prior to payment, Mr. Trivino-Perez will provide to the City Attorney written detail on fees and costs, equal to or greater than $92,500, incurred in the Conflict case as would be required in making a fee application with the court.
3. The Parties hereby fully release and forever discharge one another, as well as their respective Councilmembers. attorneys, agents, officers, employees, contractors, and volunteers (collectively the “Releasees”), from any and all rights, claims, demands, actions, and causes of action, past and present, known and unknown, which Plaintiffs may now have against them, pertaining to all claims asserted or that could have been asserted based on the facts alleged in the Conflict case.
4. Waiver Of Rights Under Civil Code Section 1542. The Parties acknowledge they have had the opportunity to review this matter with legal counsel. of their cnoosing and are familiar with the pravisions of California Civil Code section 1542, which provides as follows:
A general release does not extend to claims which the creditor does not know or suspecto exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor.
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DocuSign Envelope ID: 7-F3D87F4-2320-4261-96EF-8079DD0C5459 The Parties, being aware of this Code section, hereby expressly waive any rights they may have thereunder, or under any statutes or common law principles to similar effect.
5. Non-Agsignment of interests. Plaintiffs represent and warrant that they have nat assigned or otherwise transferred any interest in any claim that they may now have against the City arising out of the Conflict case.
6. Parties’ Remedies. Each Party shall have all rights and remedies available ai law or in equity for the other Party's breach of this Agreement including, but not limited to, an action for specific performance and/or injunction and/or an action for monetary damages.
7. Entire Agreement. This Agreement contains the sole and entire agreement and understanding among the Parties concerning the subject matter thereof, and any and all :
prior discussions, negotiations, commitments. or understandings related hereto, if any, are merged herein and superseded hereby. No representations, warranties, promises, covenants, undertakings, commitments, restrictions or other obligations, verbal, written or otherwise, expressed or implied, other than those expressly contained herein, have been made by any Party to the other conceming the subject maiter of this Agreement. a. Amendments and Waiver. This Agreement may be amended only by an agreement in writing signed by each Party hereto. No waiver of any provision or consent to any exception to the terms of this Agreement shail be effective unless in writing and signed by the Party ta be bound, and then only for the specific purpose, extent, and instance so provided. Failure on the part of any Party to enforce any of their rights under this Agreement shall nat be construed as a waiver of such rights, and a waiver by any | Party of a default hereunder in any instance shall not be construed as constituting a continuing waiver or as a waiver in other instances. .
9. Voluntary Agreement; Representation by Counsel. This Agreement is executed voluntarily by each of the Parties hereto without any duress or undue infiuence on the part of, or on behalf of, any of them. The terms of this Agreement have been negotiated by the Parties, and the language of this Agreement shail not be interpreted uncer presumptions in favor of or against any particular Party. Each of the Parties hereto represents and warrants to each other Party that hey have read and fully understand the provisions of this Agreement and have had the opportunity to discuss the Agreement with legal counsel of their own choosing. Each of the Parties hereto further represents and warrants to each other Party that their officers or other representatives who sign this Agreement on their behalf are authorized to do-so and to bind that Party, both by consent of that Party and under applicable law, and that they are executing this Agreement pursuant to that authority. The Parties, and each of them, acknowledge that each has had the opportunity te be represented in the negotiations for and in the performance of this Agreement by counsel of their own choice; that they have read this Agreement; that they have had the opportunity to have this Agreement fully explained to them by counsel of their own choice; and that each is fully aware of the contents of this Agreement and of its legal effect.
40. Binding Effect. This Agreement shall inure to the benefit of the Parties’ respective successors, assigns, representatives.
11. Governing Law. The validity, interpretation, effect, and enforcement of this Agreement, or any portion thereof, shall be governed by, and shall be construed and enforced in accordance with, ihe laws of the State of California, without regard to any choice of law provisions. All litigation or other proceedings arising out of this Agreement 3 Item 4-A
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DocuSign Envelope ID: 7F3DB7F4-2320-4261-96EF-8D79DD0C5459 to interpret or enforce this Agreemeni, or any portion thereof, or to recover for any breach thereof, shall be filed in the Los Angeles County Superior Court, unless the Parties agree in writing to an alternative venue for litigation or dispute resolution.
42. Further Assurances. Each Party shall, whenever reasonably requested by the other Party, execute or cause to be executed all such instrumenis, documenis, writings, or agreements as may be necessary to carry out the purposes of this Agreement, and each Party shall do all other acts necessary or reasonably requested by the other Party to carry out the intent and purposes of this Agreement.
43. Counterparts. This Agreement may be executed in one or more counterparts, including in portable document format ("PDF") and/or digital signatures, each of which | shail be deemed an original agreement, but all of which together shall constitute one agreement.
14. No Third Party Beneficiaries. Nothing in this Agreement is or shall be-construed to be intended to benefit any third party or create any third party beneficiary.
45. Severability. If any terms of this Agreement are deiermined by any court to be unenforceable, the remaining terms of this Agreement shall nonetheless remain in full force and effect.
IN WITNESS WHEREOF, the Parties have caused this Agreemento be duly executed as provided above.
PLAINTIEFS: Ling? APPROVED AS TO FORM:
Oscar de la Torre, an individual and Wilfredo Trivino-Perez, Attorney for Cauncitmember Plaintiffs
“Elias Serna, an individual
CITY OF SANTA MONICA, APPROVED AS TO FORM:
eemeais corporation, by:
on Douglae Gar
avid Wate city Manager Doug Sloan, City Attorney
CITY COUNCIL OF THE ATTEST:
Dotuditka me 1A MON ICA, by: DoeuSigned by: 2 . .
Hdssololr | Aine Andesyn- Winn
te Aiinéitich, Mayor enise Anderson-Warren, City Clerk
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GM-200
PLAINTIFF/PETITIONER: (/ “Ade la Ten? and Chas Seve} CASE NUMBER DEFENDANT/RESPONDENT; Crty of SATA meat ta 2iGe VOkser7
PROOF OF SERVICE BY FIRST-CLASS MAIL
NOTICE OF SETTLEMENT OF ENTIRE CASE
(NOTE: You cannot serve the Notice of Settlement.of Entire Case if you are a party in the action. The person who served :
the notice must complete this. proof of service.)
4. Lanvat least 18 years ald and not a party to:-this action. | am-a'resident of or employed in the county where the mailing took place, and my residence.or business. address is (specify): :
{0940 Wilshire Blvd. 16th Floor
Los Angeles, CA 90024
2. |served.a copy of the Notice of Settlement of Entire Case. by enclosing it in-a sealed-envelope with postage fully prepaid and (check one):
a. [__] deposited the sealed envelope with the United States Postal Service. b. [3] placed the sealed envelope for collection and processing for mailing, following this business's usual practices, with which lam readily familiar. On the same day correspondence is placed for collection and mailing, itis deposited in the ordinary course of business.with the United States Postal-Service,
3. The Notice.of Settlement of Entire Casé was. mailed:
a. on (date): July 20, 2022.
b. from (city and stale): Los Angeles, CA
4, The envelope was-addressed and mailed as follows:
a. Name of person served: c. Name of person served:
Douglas Sloan, City Attorney
Street address: 1685 -Main Street, 3rd-Floor Street address:
City: Santa Monica City:
State and zip code: CA90404 State and zip code:
b: Name:of person served: d.. Name of person served:
Carol Silberberg, Esq.
Street address: 155°N. Lake Ave., Suite 800 Street address:
City: Pasadena City:
State. and zip code: CAST101 State and zip code:
[__] Names and addresses of additional persons served are attached. (You may use form POS-O30(P).)
5. Number of pages attached OC .
| declare under penalty of perjury under the laws of the State: of California that the foregoing is true and correct.
Date: July.20, 2022
Wilfredo Trivino-Perez, Esa. Ue be bbls 7
(TYPE OR PRINT NAME-OF DECLARANT} . re ATURE-OF DECLARANT} CN-200 [Rev. January:1, 2007) NOTICE OF SETTLEMENT OF ENTIRE CASE Page 2.0f 2 This Form button after youve printed tne form. | Print this form | [ Save this form | [Clear this form | Item 4-A
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