Common use of Plaintiffs’ General Release Clause in Contracts

Plaintiffs’ General Release. In consideration of their awarded Class Representative Payments, their respective pieces of the Settlement Shares, and the other terms and conditions of the Settlement, each Plaintiff (who shall not opt out), jointly, severally, shall, and hereby fully and generally releases, discharges, and covenants not to sue the Released with respect to any and all claims, judgments, liens, losses, debts, liabilities, demands, contracts, disputed wages, obligations, guarantees, penalties, costs, expenses, attorneys’ fees, damages, indemnities, actions, causes of action, and obligations of every kind and nature in law, equity or otherwise, known or unknown, suspected or unsuspected, disclosed or undisclosed, contingent or accrued, occurring up to the execution of this Settlement, which the Plaintiffs now owns or holds or has at any time heretofore owned or held, arising out of or in any way connected with the Plaintiffs’ employment, separation of employment, or any other relationship with, any Defendant or Released Party, or any other transactions, occurrences, acts or omissions or any loss, damage or injury whatever, known or unknown, suspected or unsuspected, resulting from any act or omission by or on the part of said Defendant or Released Party, committed or omitted prior to the date of the Preliminary Approval Order. The Parties intend the Plaintiffs’ General Releases to be general and comprehensive in nature, and to release all Plaintiffs’ Claims and potential Plaintiffs’ Claims against Defendant and the Released Parties to the maximum extent permitted at law. Each Plaintiffs’ General Releases include specifically, by way of description, but not by way of limitation, any and all claims arising out of or in any way related to: (i) any interactions between the Plaintiff and any Defendant or Released Party; (ii) Plaintiff’s employment, separation of employment, contractual, and/or quasi-contractual relationship with the Defendant and the Released Parties, or any of them; (iii) any allegations as to disputed wages, remuneration, and/or other compensation, due by operation of statute, ordinance, contract, or quasi-contract; (iv) any federal, state, or local law prohibiting discrimination or retaliation on the basis of age, race, color, ancestry, religion, disability, sex, national origin, or citizenship or any other protected category, including, without limitation, claims under Title VII, the California Fair Employment and Housing Act, the California Labor Code, FLSA, the California IWC Orders, the Employee Retirement Income Security Act, and the Americans With Disabilities Act or any other similar statutes whatever the city, county, state, or country of enactment; (v) any claims under the Family and Medical Leave Act of 1993 and/or the California Family Rights Act; and (vi) any transactions, occurrences, acts, statements, disclosures, or omissions, occurring prior to the date of the Preliminary Approval Order.

Plaintiffs’ General Release. In consideration addition to the release contained in Section 2.2.1, Plaintiff on behalf of their awarded Class Representative Paymentseach of her spouses, their respective pieces of the Settlement Shareschildren, executors, representatives, guardians, wards, heirs, estates, bankruptcy estates, bankruptcy trustees, successors, predecessors, attorneys, agents and assigns, and the other terms and conditions of the Settlement, each all those who claim through them or who assert claims (or could assert claims) on her behalf (“Plaintiff (who shall not opt outReleasors”), jointly, severally, shall, release and hereby fully and generally releases, discharges, and covenants not to sue forever discharge the Released with respect to Parties from any and all actual, potential, filed, known or unknown, fixed or contingent, claimed or unclaimed, asserted or unasserted, suspected or unsuspected, claims, judgments, liens, losses, debtsdemands, liabilities, demands, contracts, disputed wages, obligations, guarantees, penalties, costs, expenses, attorneys’ fees, damages, indemnities, actionsrights, causes of action, contracts or agreements, extra-contractual claims, damages, punitive, exemplary, or multiplied damages, expenses, costs, attorneys’ fees and obligations or obligations, whether in law or in equity, accrued or unaccrued, direct, individual or representative, of every kind nature and nature in law, equity description whatsoever which they may have or otherwise, known or unknown, suspected or unsuspected, disclosed or undisclosed, contingent or accrued, occurring up claim to the execution of this Settlement, which the Plaintiffs now owns or holds or has at any time heretofore owned or held, arising out of or in any way connected with the Plaintiffs’ employment, separation of employment, or any other relationship with, any Defendant or Released Party, or any other transactions, occurrences, acts or omissions or any loss, damage or injury whatever, known or unknown, suspected or unsuspected, resulting from any act or omission by or on the part of said Defendant or Released Party, committed or omitted prior to the date have that arise before entry of the Preliminary Final Approval OrderOrder and Judgment. The Parties intend Plaintiff, on behalf of Plaintiff Releasors, fully understands that the Plaintiffs’ General Releases facts upon which this Agreement is executed may hereafter be other than or different from the facts now believed by Plaintiff and/or Settlement Class Counsel to be general true and comprehensive expressly accepts and assumes the risk of such possible difference in nature, facts and to release all Plaintiffs’ Claims and potential Plaintiffs’ Claims against Defendant and the Released Parties to the maximum extent permitted at law. Each Plaintiffs’ General Releases include specifically, by way of description, but not by way of limitation, agrees that this Agreement shall remain effective notwithstanding any and all claims arising out of or in any way related to: (i) any interactions between the Plaintiff and any Defendant or Released Party; (ii) Plaintiff’s employment, separation of employment, contractual, and/or quasi-contractual relationship with the Defendant and the Released Parties, or any of them; (iii) any allegations as to disputed wages, remuneration, and/or other compensation, due by operation of statute, ordinance, contract, or quasi-contract; (iv) any federal, state, or local law prohibiting discrimination or retaliation on the basis of age, race, color, ancestry, religion, disability, sex, national origin, or citizenship or any other protected category, including, without limitation, claims under Title VII, the California Fair Employment and Housing Act, the California Labor Code, FLSA, the California IWC Orders, the Employee Retirement Income Security Act, and the Americans With Disabilities Act or any other similar statutes whatever the city, county, state, or country of enactment; (v) any claims under the Family and Medical Leave Act of 1993 and/or the California Family Rights Act; and (vi) any transactions, occurrences, acts, statements, disclosures, or omissions, occurring prior to the date of the Preliminary Approval Order.such difference in

Plaintiffs’ General Release. In consideration addition to the release contained in Section 2.2.1, Plaintiff on behalf of their awarded Class Representative Paymentseach of his spouses, their respective pieces of the Settlement Shareschildren, executors, representatives, guardians, wards, heirs, estates, bankruptcy estates, bankruptcy trustees, successors, predecessors, attorneys, agents and assigns, and the other terms and conditions of the Settlement, each all those who claim through them or who assert claims (or could assert claims) on his behalf (“Plaintiff (who shall not opt outReleasors”), jointly, severally, shall, release and hereby fully and generally releases, discharges, and covenants not to sue forever discharge the Released with respect to Parties from any and all actual, potential, filed, known or unknown, fixed or contingent, claimed or unclaimed, asserted or unasserted, suspected or unsuspected, claims, judgments, liens, losses, debtsdemands, liabilities, demandsrights, contractscauses of action, disputed wagescontracts or agreements, obligationsextra-contractual claims, guaranteesdamages, penaltiespunitive, exemplary, or multiplied damages, expenses, costs, expenses, attorneys’ fees, damagesand or obligations, indemnitieswhether in law or in equity, actionsaccrued or unaccrued, causes of actiondirect, and obligations individual or representative, of every kind nature and nature description whatsoever which they may have or claim to have that arise before entry of the Final Approval Order and Judgment. Plaintiff, on behalf of Plaintiff Releasors, fully understands that the facts upon which this Agreement is executed may hereafter be other than or different from the facts now believed by Plaintiff and/or Settlement Class Counsel to be true and expressly accepts and assumes the risk of such possible difference in law, equity or otherwise, known or unknown, suspected or unsuspected, disclosed or undisclosed, contingent or accrued, occurring up facts and agrees that this Agreement shall remain effective notwithstanding any such difference in facts. With respect to the execution release in this Section 2.2.2, Plaintiff, on behalf of this Settlement, which the Plaintiffs now owns or holds or has at any time heretofore owned or held, arising out of or in any way connected with the Plaintiffs’ employment, separation of employment, or any other relationship with, any Defendant or Released Party, or any other transactions, occurrences, acts or omissions or any loss, damage or injury whatever, known or unknown, suspected or unsuspected, resulting from any act or omission by or on the part of said Defendant or Released Party, committed or omitted prior to the date of the Preliminary Approval Order. The Parties intend the Plaintiffs’ General Releases to be general and comprehensive in nature, and to release all Plaintiffs’ Claims and potential Plaintiffs’ Claims against Defendant and the Released Parties to the maximum extent permitted at law. Each Plaintiffs’ General Releases include specifically, by way of description, but not by way of limitation, any and all claims arising out of or in any way related to: (i) any interactions between the Plaintiff and any Defendant or Released Party; (ii) Plaintiff’s employment, separation of employment, contractual, and/or quasi-contractual relationship with the Defendant and the Released Parties, or any of them; (iii) any allegations as to disputed wages, remuneration, and/or other compensation, due by operation of statute, ordinance, contract, or quasi-contract; (iv) any federal, state, or local law prohibiting discrimination or retaliation on the basis of age, race, color, ancestry, religion, disability, sex, national origin, or citizenship or any other protected category, including, without limitation, claims under Title VII, the California Fair Employment and Housing Act, the California Labor Code, FLSA, the California IWC Orders, the Employee Retirement Income Security Act, and the Americans With Disabilities Act or any other similar statutes whatever the city, county, state, or country of enactment; (v) any claims under the Family and Medical Leave Act of 1993 and/or the California Family Rights Act; and (vi) any transactions, occurrences, acts, statements, disclosures, or omissions, occurring prior to the date of the Preliminary Approval Order.Plaintiff