SETTLEMENT AGREEMENTSettlement Agreement • December 23rd, 2019 • California
Contract Type FiledDecember 23rd, 2019 JurisdictionThis Settlement Agreement (“Agreement,” the terms of which are sometimes referred to as the “Settlement”) is entered into by and between Walter Bochenek (“Bochenek” or “Plaintiff”), on behalf of himself and all other individuals who are members of the Class defined in Section III below, on the one hand, and M2 Media Group, LLC (“M2”) and Blue Dolphin Group, LLC (“Blue Dolphin”) (collectively, “Defendants”), on the other hand. Plaintiff and Defendants are each referred to herein as a “party,” and collectively as the “parties.”