Settlement Class Representative’s General Release Clause Samples

Settlement Class Representative’s General Release. In addition, upon the Final 21 Effective Date, Plaintiff ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇, for herself, and her heirs, successors, predecessors, 22 attorneys, agents, representatives and assigns, fully and forever releases and discharges the 23 Released Parties from any and all charges, complaints, claims, liabilities, obligations, promises, 24 agreements, controversies, damages, actions, causes of action, suits, rights, demands, costs, losses, 25 debts, and expenses (including back wages, penalties, liquidated damages, and attorneys’ fees and 26 costs actually incurred) of any nature whatsoever, from the beginning of time through the date of 27 her signature on this Settlement, known or unknown, suspected or unsuspected, including but not 28 limited to all claims arising out of, based upon, or relating to her employment with Defendant or the 1 remuneration for such employment. Without limiting the generality of the foregoing, Plaintiff 2 expressly releases all claims which were or could have been raised in the Action and all claims or 3 rights arising out of alleged violations of any contracts, express or implied (including but not 4 limited to any contract of employment); any contract or covenant of good faith or fair dealing 5 (express or implied); wrongful discharge; any tort, including negligence, fraud, misrepresentation 6 under California Labor Code section 970, negligent infliction of emotional distress, intentional 7 infliction of emotional distress, assault, battery, and defamation; any “retaliation” claims; any 8 claims relating to any breach of public policy; any legal restrictions on Defendant’s right to 10 statute, regulation, or ordinance, including, without limitation: (1) Title VII of the Civil Rights Act 11 of 1964 (race, color, religion, sex, and national origin discrimination or harassment, including 12 retaliation for reporting discrimination or harassment); (2) 42 U.S.C. § 1981 (discrimination); (3) 13 sections 503 and 504 of the Rehabilitation Act of 1973 (disability discrimination); (4) Equal Pay 14 Act, 29 U.S.C. § 209(4)(1) (equal pay); (5) Americans with Disabilities Act, 42 U.S.C. § 12100 et 15 seq. (disability discrimination); (6) Family and Medical Leave Act, 29 U.S.C. § 2601 et seq.