Defendant’s Reasons for Settlement. Defendants recognize that the defense of this litigation will be protracted and expensive. Substantial amounts of time, energy, and resources of Defendants have been and, unless this Settlement is made, will continue to be devoted to the defense of the claims asserted by Plaintiff. Defendants, therefore, have agreed to settle in the manner and upon the terms set forth in this Agreement to put to rest the Released Claims.
Defendant’s Reasons for Settlement. Defendants have concluded that any further defense of this litigation would be protracted and expensive for all Parties. Substantial amounts of Defendants’ time, energy, and resources have been and, unless this Settlement is completed, will continue to be devoted to, the defense of the claims asserted by Plaintiffs and Settlement Class Members. Defendants have also taken into account the risks of further litigation in reaching their decision to enter into this Settlement. Even though Defendants continue to contend that they are not liable or jointly and severally liable for any of the claims set forth by Plaintiffs in the Actions, Defendants have agreed, nonetheless, to settle in the manner and upon the terms set forth in this Agreement to put to rest the claims in the Actions. Defendants contend that they have complied with all applicable state, federal, and local laws.
Defendant’s Reasons for Settlement. Defendant and its Counsel recognize that the 25 defense of this litigation will be protracted and expensive. Substantial amounts of time, energy, and 26 resources of Defendant has been and, unless this Settlement is made, will continue to be devoted to 27 the defense of the claims asserted by Plaintiff. Defendant, therefore, has agreed to settle in the manner 28 and upon the terms set forth in this Agreement to put to rest the Released Claims.
Defendant’s Reasons for Settlement. Defendant recognizes that the defense of this litigation will be protracted and expensive for all Parties. Substantial amounts of Defendant’s time, energy, and resources have been and, unless this Settlement is made, will continue to be devoted to the defense of the claims asserted by Plaintiffs. Defendant has also taken into account the risks of further litigation in reaching its decision to enter into this Settlement. Despite continuing to contend that it is not liable for any of the claims set forth by Plaintiffs, Defendant has, nonetheless, agreed to settle in the manner and upon the terms set forth in this Agreement to put to rest the claims as set forth in the Actions.
Defendant’s Reasons for Settlement. Defendants have concluded that any further defense of this litigation would be protracted and expensive for all Parties. Substantial amounts of Defendants’ time, energy, and resources have been and, unless this Settlement is completed, will continue to be devoted to, the defense of the claims asserted by Plaintiff and Settlement Class Members. Defendants have also accounted for the risks of further litigation in reaching their decision to enter into this Settlement. Even though Defendants continue to contend that they are not liable or jointly and severally liable for any of the claims set forth by Plaintiff in the Actions, Defendants have agreed, nonetheless, to settle in the manner and upon the terms set forth in this Agreement to put to rest the claims in the Actions. Defendants contend that they have complied with all applicable state, federal, and local laws, and that A1X and Greenwich Logistics were contractually obligated to do so as to their delivery driver employees. Defendants and their counsel also agreed to compromise claims based on significant changes and uncertainty under California law as to the extent in which Plaintiff’s allegations of “joint employer” or “client employer” extend even though A1X and Greenwich Logistics were completely separate entities engaged in contractual service provider relationships with Amazon.
Defendant’s Reasons for Settlement. 2.15. Defendant has concluded that any further defense of the Actions would be protracted and expensive. Substantial amounts of Defendant’s time, energy, and resources have been and, unless this Settlement is made, will continue to be devoted to the defense of the Released Class Claims asserted by Plaintiffs on behalf of Class Members, and the Released PAGA Claims asserted by Plaintiffs on behalf of the State of California and Affected Employees. Defendant has also considered the risks of further litigation in reaching its decision to enter into this Settlement. Although Defendant strongly disputes Plaintiffs’ claims in the Actions and contends no Class Members or Affected Employees are entitled to compensation for the conduct alleged in the Actions, Defendant has nonetheless agreed to settle in the manner and upon the terms set forth in this Agreement to put to rest the asserted claims and to avoid further protracted litigation. Defendant agrees that the Settlement set forth in this Settlement Agreement is fair, reasonable, and adequate.
Defendant’s Reasons for Settlement. Defendant recognizes that the defense of this litigation will be protracted and expensive. Substantial amounts of time, energy, and resources of Defendant have been and, unless this Settlement is made, will continue to be devoted to the defense of the claims asserted by Plaintiff. As a not-for-profit credit union dedicated to fostering financial health and well being for military veterans and their families, Defendant would prefer to continue to focus on its important mission. Defendant, therefore, has agreed to settle in the manner and upon the terms set forth in this Agreement to put to rest the Released Claims.
Defendant’s Reasons for Settlement. Defendants have concluded that any 2 further defense of this litigation would be protracted and expensive for all Parties.
Defendant’s Reasons for Settlement. Defendant recognizes that the defense of this litigation will be protracted and expensive. Substantial amounts of time, energy, and resources of Defendant have been and, unless this Settlement is made, will continue to be devoted to the defense of the claims asserted by Plaintiff. Defendant, therefore, has agreed to settle in the manner and upon the terms set forth in this Agreement to put to rest the Released Claims. Defendant’s Denial of Wrongdoing. Defendant generally and specifically denies any and all liability or wrongdoing of any sort with regard to any of the claims alleged, makes no concessions or admissions of liability of any sort, and contends that for any purpose other than settlement, the Class Action is not appropriate class treatment. Defendant also asserts several defenses to the claims and has denied any wrongdoing or liability arising out of any of the alleged facts or conduct in the Class Action. Neither this Agreement, nor any document referred to or contemplated herein, nor any statements, discussions, or communications, nor any action taken to carry out this Agreement, is or may be construed as, or may be used as an admission, concession, or indication by or against Defendant or any of the Released Parties of any fault, wrongdoing, or liability whatsoever. Nor should the Agreement be construed as an admission that Plaintiff can serve as adequate Class Representative. There has been no final determination by any court as to the merits of the claims asserted by Plaintiff against Defendant or as to whether a class or classes should be certified, other than for settlement purposes only. Plaintiff’s Claims. Plaintiff asserts that Defendant’s defenses are without merit. Neither this Agreement nor any documents referred to or contemplated herein, nor any action taken to carry out this Agreement is, may be construed as, or may be used as an admission, concession or indication by or against Plaintiff, Class Members, or Class Counsel as to the merits of any claims or defenses asserted, or lack thereof, in the Class Action. However, in the event that this Settlement is finally approved by the Court, none of Plaintiff, Class Members, or Class Counsel will oppose Defendant’s efforts to use this Agreement to prove that Plaintiff and Class Members have resolved and are forever barred from re-litigating the Released Claims.
Defendant’s Reasons for Settlement. Defendant and Defendant’s Counsel concur that this Agreement is fair, adequate and reasonable and in the best interest of the Settlement Class and each Settlement Class Member.
