Plaintiff Sample Clauses

Plaintiff. “Plaintiff” refers to the Class Representative, ▇▇▇▇▇▇ ▇▇▇▇▇▇▇.

Plaintiff. Davia is an individual residing in the State of California who seeks to promote awareness of exposure to toxic chemicals and improve human health by reducing or eliminating hazardous substances contained in consumer products.

Plaintiff. ▇▇▇▇▇▇ is an individual residing in California who seeks to promote 7 awareness of exposures to toxic chemicals and improve human health by reducing or eliminating 8 hazardous substances contained in consumer products.

Plaintiff. As of the Effective date, in addition to the releases set forth in Sections III.G.1 and III.G.2 above, Plaintiff hereby fully and finally releases Defendants and the other Released Parties from any and all claims, known or unknown, asserted or that might have been asserted, that she has or might have against Defendants and Released Parties (“Plaintiff’s Released Claims”). Plaintiff’s Released Claims include without limitation breaches of contract, whether written, oral or implied; violations of any public policy; tort claims, including but not limited to intentional infliction of emotional distress and negligent infliction of emotional distress, defamation, misrepresentation, and fraud; retaliation claims; common law claims; any other claims for damages, costs, fees, or other expenses, including attorneys’ fees; and any violations of the following statutes, laws, and regulations: Title VII of the Civil Rights Act of 1964, as amended; the Civil Rights Act of 1991; the Americans with Disabilities Act of 1990, as amended; the Age Discrimination in Employment Act of 1967, as amended; the Older Workers Benefit Protection Act; the Family and Medical Leave Act of 1993, as amended; the Fair Labor Standards Act; the Washington Revised Code, the Washington Administrative Code, and any other federal, state, or local civil employment law, statute, regulation, or ordinance capable of being released by Plaintiff, excluding any claims that cannot be released as a matter of law.

Plaintiff. Upon the occurrence of the Effective Date, Plaintiff generally, unconditionally, irrevocably and absolutely releases and discharges the Released Parties from any and all claims, transactions or occurrences between them that occurred during the Class Period, to the fullest extent permitted by law (“Plaintiff’s Released Claims”). This release of Plaintiff’s Released Claims unconditionally, irrevocably and absolutely releases and discharges the Released Parties from any claim that Plaintiff could maintain in any action against any Released Party that occurred during the Class Period. Notwithstanding the foregoing, nothing in this Settlement Agreement waives or releases any rights which as a matter of law cannot be waived and released by private agreement, including rights to sue to enforce this Agreement and rights to unemployment benefits and workers’ compensation benefits and claims outside the Class Period. Plaintiff acknowledges that she may discover facts or law different from, or in addition to the facts or law that she knows or believes to be true with respect to the claims and matters released by way of this Agreement and agrees, nonetheless, that this Agreement and the releases contained in it shall be and remain effective in all respects, notwithstanding such different or additional facts or the discovery of them. The Parties declare and represent that they intend this Agreement to be complete and not subject to any claim of mistake, and that the releases herein express full and complete releases, and that they intend that the releases herein shall be final and complete. The Parties execute this release with the full knowledge that this release of the Plaintiff’s Released Claims cover all possible claims by Plaintiff against the Released Parties, to the fullest extent permitted by law. To the extent permitted by law, Plaintiff expressly waives her right to recovery of any type, including damages, penalties, or reinstatement, in any administrative or court action, whether state or federal, and whether brought by Plaintiff or on Plaintiff’s behalf, related in any way to the matters released herein. Notwithstanding the provisions of section 1542, and for the purpose of implementing a full and complete release and discharge of all of Plaintiff’s Released Claims, Plaintiff expressly acknowledges that this settlement is intended to include in its effect, without limitation, all Plaintiff’s Released Claims which Plaintiff does not know or suspect to exist ...

Plaintiff. 10 5. The FTC is an independent agency of the United States Government 11 created by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC 12 Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or 13 affecting commerce. 14 6. The FTC is authorized to initiate federal district court proceedings, by 15 its own attorneys, to enjoin violations of the FTC Act and to secure such equitable 16 relief as may be appropriate in each case, including rescission or reformation of 17 contracts, restitution, the refund of monies paid, and the disgorgement of ill-gotten 18 monies. 15 U.S.C. § 53(b). 19 DEFENDANTS 20 7. Defendant National Awards Service Advisory, LLC, also doing 21 business as Prize Information Bureau and Award Notification Bureau, is a Nevada 22 limited liability company with mailing addresses at P.O. Box 98699 and P.O. Box 23 98776, in Las Vegas, Nevada 89193. National Awards Service Advisory, LLC, 24 transacts or has transacted business in this district and throughout the United

Plaintiff. Plaintiff will enter into an individual settlement agreement, which shall provide for an Individual Settlement Payment, as provided for in this Agreement, and which shall provide for a broad release. This release, waiver and discharge of all claims shall include, but will not be limited to, any and all claims arising out of the Action, as well as additional claims described in the Individual Settlement Agreement

Plaintiff. 3 8. The FTC is an independent agency of the United States Government 4 created by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC 5 Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or 6 affecting commerce. 7 9. The FTC is authorized to initiate federal district court proceedings, by 8 its own attorneys, to enjoin violations of the FTC Act and to secure such equitable 9 relief as may be appropriate in each case, including rescission or reformation of 10 contracts, restitution, the refund of monies paid, and the disgorgement of ill-gotten 11 monies. 15 U.S.C. §§ 53(b), 56(a)(2)(A). 12 DEFENDANTS

Plaintiff. As of the Effective Date and upon full funding, Plaintiff generally releases and discharges the Released Parties from any and all claims, transactions or occurrences between them that occurred during the Class Period, inclusive of the Released Class Claims, the Released PAGA Claims, and the claims arising from his prior employment with Defendant and separation of said employment with Defendant. (“Plaintiff’s Released Claims”). Notwithstanding the foregoing, this waiver and release of claims does not extend to any rights which as a matter of law cannot be waived and released by private agreement, including rights to ▇▇▇ to enforce this Agreement and rights to vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ compensation benefits and claims outside the Class Period.