SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • June 13th, 2025
This Settlement Agreement and Release (“Settlement Agreement”) is made by and between David Tovar, Sr., minors D.T.M. and J.M. by and through their guardian ad litem Elliot Tovar, minor Plaintiff D.T. by and through his guardian ad litem Valerie Hall, minor D.T.J. by and through his guardian ad litem Marilyn Presho, and the Estate of David Tovar, Jr. (hereafter “Plaintiffs”), and the City of San Jose (hereafter “CITY”). “Parties,” when referenced herein, includes Plaintiffs and CITY collectively.