CLASS ACTION AND PAGA SETTLEMENT AGREEMENT AND GENERAL RELEASEClass Action and Paga Settlement Agreement and General Release • January 8th, 2019 • Bender
This Class Action and Private Attorneys General Act (“PAGA”) Action Settlement Agreement and General Release (“Settlement” or “Settlement Agreement”) is entered into, for good and valuable consideration, by and between Chandler Bender and Julio Rojas (the named plaintiffs in Bender v. Les Schwab Tire Centers of California, Inc. et al. (Case No. 34-2017- 00218185, Sacramento Sup. Ct.)) and Amy Mettler (the named plaintiff in Mettler v. Les Schwab Tire Centers of California, Inc. (Case No. STK-CV-UOE-2018-00476, San Joaquin Sup. Ct.)) (jointly, “Plaintiffs”), on behalf of themselves and the members of the Settlement Class (as defined herein), with the assistance and approval of Class Counsel (as defined herein), on the one hand, and Les Schwab Tire Centers of California, Inc. and Les Schwab Tire Centers of Central California, Inc. (collectively, “Defendants”) with the assistance of their counsel of record in the Bender Litigation and Mettler Litigation (as those terms are defined herein)
