SETTLEMENT AND RELEASE OF ALL CLAIMS AGREEMENTSettlement Agreement • December 11th, 2020 • California
This Settlement and Release of All Claims Agreement (“Agreement”), effective as of November 13, 2020 (the “Effective Date”), is entered into by and between Plaintiffs American Civil Liberties Union of Southern California, First Amendment Coalition, Kilah Oats, Lotisha Davidson, Tanisha Brown, Tameca Spriggs, and Janie Randle (collectively, “Plaintiffs”), on the one hand, and Defendants Tamarah Harber-Pickens (“Harber-Pickens”), in her official capacity as Court Executive Officer / Clerk of the Superior Court of California, County of Kern, and Judith K. Dulcich (“Dulcich”), in her official capacity as Presiding Judge of the Superior Court of California, County of Kern (collectively, Harber-Pickens and Dulcich are referred to as “KCSC”), on the other hand. Plaintiffs and KCSC are referred to herein collectively as the “Parties,” and individually as a “Party.”