Release by Class Members. It is the desire of the Plaintiff, Class Members (except those who exclude themselves from the Settlement), and Defendant to fully, finally, and forever settle, compromise, and discharge the claims asserted in the Action. Upon the Final Approval by the Court of this Settlement Agreement, and except as to such rights or claims as may be created by this Settlement Agreement, the Class Members shall fully release and discharge the Released Parties from any and all Released Claims for the entire Released Claims Period. This release shall be binding on all Class Members including each of their respective attorneys, agents, spouses, executors, representatives, guardians ad litem, heirs, successors, and assigns, and shall inure to the benefit of the Released Parties, who shall have no further or other liability or obligation to any Settlement Class Member with respect to the Released Claims, except as expressly provided herein. DELSON, P. S Center 8th Street N 55402. 2136 30. 1000
Release by Class Members. Each Class Member waives and releases the Released Parties, and each of them, from and against any and all claims, whether known or unknown, suspected or not suspected to exist, against the Released Parties, or any of them, arising out of the allegations of the First Amended Complaint on file in the Action during the Class Period, including but not limited to claims for straight time and overtime wages, meal and rest period violations, meal period premiums, rest period premiums, waiting time penalties, and accurate and complete wage statements, or arising under Labor Code §§ 201, 202, 203, 226, 226.7, 510, 512, 516, 558.1, 1194, 1194.2, 1198, 1199 or Sections 11 and 12 of Wage Order 1-2001, or under California Business and Professions Code § 17200, et seq. for violations of the above-cited Labor Code sections as well as Section 1174, and claims for attorney’s fees and costs associated with any of the above claims. Participating Class Members do not release any other claims, such as claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation or claims based on facts occurring outside the Class Period.
Release by Class Members. On the Effective Date, all Class and Subclass Members hereby fully, finally, and forever release, relinquish, and discharge any and all injunctive, equitable, or declaratory relief claims, liens, demands, actions, and causes of action of any nature that they have, had, may have, or could have raised against Defendants and Released Parties, arising out of any of the legal and/or factual allegations and/or legal claims of the Action.
Release by Class Members. 1. Upon the Effective Date and subject to Defendants’ full payment of all sums required by this Settlement Agreement, the Class Representative and all Class Members who do not submit a timely and valid request for exclusion from the Settlement Class hereby release Defendants and the Released Parties from all claims that were or reasonably could have been asserted based on the factual allegations contained in the Action and which arose during the Class Period, including claims for violation of Penal Code Sections 632, 632.7 or 637.2 or any other State or Federal law, statute, regulation or ordinance imposing liability and/or obligations related to the recording of telephone calls.
Release by Class Members. Upon the Effective Date, the Class Representative and all Class Members, individually and as assignees of Horizon subscribers, together with their respective current and former officers, directors, employees, attorneys, heirs, executors, administrators, agents, legal representatives, professional corporations, partnerships, assigns, assignors, successors and predecessors (collectively, the “Class Releasing Parties”), shall forever release and discharge all claims, including any and all rights and liabilities of any nature, including, but not limited to, appeals, actions, claims, demands, causes of action, obligations, damages, debts, charges, attorneys’ fees, costs, arbitrations, forfeitures, judgments, indebtness, liens, and losses of any kind, source, or character, whether arising out of federal or state law, whether known or unknown, whether asserted or unasserted, whether asserted by any Class Releasing Party on its own behalf or on behalf of any other person or entity, arising on or before the Effective Date, whether in contract, express or implied, tort, at law or in equity, or arising under or by virtue of any statute or regulation, by reason of, arising out of, or in any way related to Horizon’s payment, reimbursement or administration of any claim for benefits under any insured or self-insured plan to licensed ambulatory surgery centers or unlicensed single surgical suites located in New Jersey for Out-of-Network Services, whether any such Claim was or could have been asserted by any Class Releasing Party on its own behalf or on behalf of other Persons, including, but not limited to, as assignee of Horizon subscribers, (the “Class Released Claims”), against Horizon and any of its former, present and future assigns, predecessors, successors, affiliates, parent companies, subsidiaries, controlled companies, employees, officers, directors, principals, agents and self insured groups, including, but not limited to the State Health Benefits Program (collectively, the “Class Released Party”).
Release by Class Members. Following the Effective Date and immediately upon payment by Defendants of the full Settlement Amount, all Class Members who have not timely requested exclusion from the Settlement, as well as their respective heirs, assigns, executors, administrators, successors, and agents, shall be deemed to release, resolve, relinquish, and discharge each and all of the Released Parties (as defined above) from each of the Released Claims (as defined below). For purposes of this paragraph, “Released Claims” means any and all causes of action or claims for relief, including but not limited to injunctive relief, actual damages, nominal damages, statutory damages, punitive damages, restitution, disgorgement, attorneys’ fees and costs, and/or any other form of monetary consideration whatsoever, whether known or unknown, suspected or unsuspected, for any and all claims by the Settlement Class Members that have been pled in the Action, or that could have been pled in this Action, that arise out of or relate to the causes of action, allegations, practices, and conduct at issue in the Complaint, the First Amended Complaint, and the proposed Second Amended Complaint.
Release by Class Members. 1. In accordance with the provisions of the Final Order, for good and sufficient consideration, the receipt of which is hereby acknowledged, upon the Effective Date Plaintiff and each Class Member shall be deemed to have, and by operation of the Final Order shall have, fully, finally and forever released, relinquished and discharged all Released Claims against the Released Parties.
Release by Class Members. 1. In accordance with the provisions of the Final Order, for good and sufficient consideration, the receipt of which is hereby acknowledged, upon Complete Settlement Approval, Representative Plaintiffs and each Settlement Class Member shall be deemed to have, and by operation of the Final Order shall have, fully, finally and forever released, relinquished, and discharged all Released Claims against the Released Parties.
Release by Class Members. In exchange for receiving payments under the Settlement, Plaintiff and each Class Member who has not opted out of the Settlement (which would include you) shall be deemed to have fully, finally, and forever released Urban Releasees1 from any and all claims, obligations, demands, rights, causes of action, and liabilities against Urban Releasees, whether in law or equity that have been asserted or that could have been asserted in the Complaint, the First Amended Complaint, the Second Amended Complaint, and any amendments thereto; or that could have been asserted in the Complaint, the First Amended Complaint, the Second Amended Complaint, and any amendments thereto, based on the facts, claims and/or allegations pled therein (“Released Class Claims”). Released Class Claims include, but are not limited to, claims for failure to pay minimum wage, failure to pay overtime or pay overtime at the correct rate of pay, failure to pay for all hours worked (off-the-clock work), failure to provide meal periods, failure to provide rest periods, failure to pay premiums at the correct rate of pay, failure to timely pay final wages and wages earned during employment, failure to provide accurate, itemized wage statements, and failure to maintain ccurate and complete records, and includes all claims for recovery of compensation, ertime pay, minimum wage,
Release by Class Members. It is the desire of the Plaintiff, Class Members (except those who 6 exclude themselves from the Settlement), and Defendant to fully, finally, and forever settle, compromise, and 7 discharge the claims asserted in the Action. Upon the Final Approval by the Court of this Settlement 8 Agreement, and except as to such rights or claims as may be created by this Settlement Agreement, the Class 9 Members shall fully release and discharge the Released Parties from any and all Released Claims for the entire 10 Released Claims Period. This release shall be binding on all Class Members who have not timely submitted a 11 valid and complete Request for Exclusion, including each of their respective attorneys, agents, spouses, 12 executors, representatives, guardians ad litem, heirs, successors, and assigns, except that claims under the FLSA 13 shall be released only by Class Members who submit a valid Claim Form. This release shall inure to the benefit 14 of the Released Parties, who shall have no further or other liability or obligation to any Settlement Class 15 Member with respect to the Released Claims, except as expressly provided herein.
