Class Action Settlement Agreement and Release Sample Contracts

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION
Class Action Settlement Agreement and Release • August 3rd, 2021 • California

This Amended Class Action Settlement Agreement and Release (“Settlement Agreement”), dated as of the date of the last signature below, is made and entered into pursuant to Federal Rules of Civil Procedure 23(a), 23(b)(2), 23(b)(3) and 23(e) between and among: (1) Roberta Bilbrey, Jimmy Banh, Mark Peoples, Jamal Samaha, George Quinlan, Sarah Gravlin, Alexis Chisari, Michael Brumer, Dave Jahsman, John Bartholomew, Vimal Lawrence, Mark Klein, Adam Pryor, Srikarthik Subbarao, Daniel Allan, Paul Gonzales, Eric Faden, and Kristen Gratton (collectively, “Named Plaintiffs”), on behalf of themselves and as representatives of the Settlement Class defined below (the Named Plaintiffs and members of the Settlement Class are collectively referred to as “Settlement Class Members”) on the one hand, and (2) Defendant American Honda Motor Co., Inc. (“AHM”), on the other hand, (collectively with Named Plaintiffs, the “Parties”) by and through their undersigned counsel, in order to fully and finally settl

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CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • January 5th, 2018 • New York

This Class Action Settlement Agreement and Release (the “Agreement”) is entered into between Plaintiff Jose Ortega, on his own behalf and on behalf of all Settlement Class Members as defined herein, Plaintiff Joce Martinez, on his own behalf, and Defendants Uber Technologies, Inc., Rasier, LLC, and Uber USA, LLC (collectively, “Defendants”), and is subject to the terms and conditions set forth herein, and the final approval of the U.S. District Court for the Eastern District of New York.

AMENDED CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • November 9th, 2020

Plaintiffs ARMEN KOJIKIAN and TIME TRADERS, INC. (“Plaintiffs or “Class Representatives”), on behalf of themselves and all others similarly situated and by and through their counsel, and Defendant American Honda Motor Co., Inc. (“AHM” or “Defendant”), by and through its counsel, hereby enter into this Settlement Agreement and Release (“Settlement Agreement”), subject to Court approval. The Parties in consideration of the mutual promises, agreements, and covenants contained herein, the sufficiency and receipt of which are hereby acknowledged, stipulate and agree as follows:

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • February 11th, 2024 • Massachusetts

This Class Action Settlement Agreement and Release, is made and entered into by and among Plaintiffs Jasmyn Bickham, Amanda Bailey, and Lisa Gordon (collectively, “Plaintiffs” or “Class Representatives”), for themselves individually and on behalf of the Settlement Class, and Defendant Reprosource Fertility Diagnostics, Inc. (“ReproSource”). This Settlement Agreement fully and finally resolves and settles all of Plaintiffs’ and the Settlement Class’s Released Claims, and subject to the terms and conditions hereof, and subject to the Court’s approval.

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • January 28th, 2022 • Illinois

This Class Action Settlement Agreement and Release is entered into by and among Philip Charvat, the Settlement Class Members, Carnival Corporation & PLC, Royal Caribbean Cruises, Ltd., and NCL (Bahamas) Ltd., Resort Marketing Group, Inc. and Elizabeth Valente. This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle this Action and the Released Claims with prejudice, upon and subject to the terms and conditions of this Agreement, and subject to the final approval of the Court.

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • November 15th, 2020 • Pennsylvania

WHEREAS, on or about November 1, 2016, Plaintiffs Kao and T.S. Kao filed a class action complaint against Defendant CardConnect in the United States District Court for the Eastern District of Pennsylvania under Case No. 2:16-cv-05707 (Dkt. 1).

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • June 14th, 2023

This Settlement and Release Agreement (“Settlement Agreement” or “Settlement”) is entered into by and among Lucius Veiga, Alex Parker Zimmerman, Courtnie Patterson, Trevonte Johnson, Cody Powell, Daniel Fee, and Brittany Harvey (collectively, “Plaintiffs”), both individually and on behalf of the Settlement Class, and Respondus, Inc. (“Respondus” or

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • August 9th, 2019 • Connecticut
CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • October 4th, 2022

This Class Action Settlement Agreement and Release (the “Agreement”) is entered into between Plaintiff Petrolin Kelly (“Plaintiff”), on her own behalf and as a proposed class representative on behalf of each of the Settlement Class Members pursuant to this Agreement, on the one hand, and Defendant Blue Tarp reDevelopment, LLC (“Defendant”), on the other hand, to voluntarily and completely settle and resolve the above-captioned matter subject to the terms and conditions set forth herein. This Agreement pertains to all claims that have been and/or are asserted, or reasonably could have been asserted, in the Action based on the facts and/or theories alleged in any of the pleadings that have been and/or will be filed therein, to the fullest extent reflected herein, subject to approval of the Court. For purposes of this Agreement, Plaintiff and Defendant are referred to individually as a “Party” and collectively as the “Parties.” All capitalized terms used in this Agreement have the defined

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE‌‌‌
Class Action Settlement Agreement and Release • October 6th, 2023 • New York

This Class Action Settlement Agreement and Release (“Agreement”) is made and entered into by and between the Class Representatives on behalf of the Settlement Class as defined below, on the one hand, and Colgate-Palmolive Company (“Colgate-Palmolive”) (collectively, the “Parties”) on the other hand.

EXHIBIT A
Class Action Settlement Agreement and Release • April 2nd, 2021 • New York

LARRY W. JANDER, RICHARD J.WAKSMAN, and all other individuals similarly situated, Plaintiffs, v. RETIREMENT PLANS COMMITTEE OF IBM, RICHARD CARROLL, MARTIN SCHROETER, and ROBERT WEBER, Defendants. No. 1:15-cv-03781-WHP

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • June 24th, 2021 • Massachusetts

(“Agreement”), made on June 24, 2021 (“Execution Date”), subject to final approval by the United States District Court for the District of Massachusetts (“Court”), is between (a) Gracie White f/k/a Gracie Dorneus (“Class Representative”), individually and as the representative of the Class, and (b) Ally Financial Inc. The Class Representative, Ally Financial Inc., and the Class are sometimes individually called a “Party” and collectively called the “Parties.” Other capitalized terms are defined in Paragraph 2 or elsewhere in this Agreement.

AMENDED CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE‌
Class Action Settlement Agreement and Release • April 10th, 2020 • Missouri

IT IS HEREBY AGREED, by and between MARK PIROZZI (“PIROZZI”) and KEILA GREEN (“GREEN”) (collectively, “PLAINTIFFS” or “CLASS REPRESENTATIVES”),

EXHIBIT A
Class Action Settlement Agreement and Release • December 29th, 2021 • California
CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • August 20th, 2019 • California

This Settlement Agreement and Release (“Agreement”) is entered into by Plaintiff Shawn Esparza (“Plaintiff”), individually and on behalf of the class of persons she seeks to represent, and by Defendant SmartPay Leasing LLC, improperly sued as SmartPay Leasing, Inc. (“Defendant” or “SmartPay”). Plaintiff and Defendant are referred to collectively in this Agreement as the “Parties.”

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • March 16th, 2022 • Washington
CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • January 24th, 2024 • New York

This Class Action Settlement Agreement and Release, dated June 16, 2023, is made and entered into by and among the Class Representatives (defined below), for themselves individually and on behalf of the Settlement Class (defined below), and Defendant Empress Ambulance Service, LLC (“Empress”) (collectively, the “Parties”). This Agreement fully and finally resolves and settles all of Plaintiffs’ and the Settlement Class’s Released Claims, upon and subject to the terms and conditions hereof, and subject to the Court’s approval.

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • April 11th, 2023 • California

This Class Action Settlement Agreement and Release (the “Settlement Agreement”) is entered into by and between Plaintiffs David Vance, Roxie Vance, and Carla Shultz (“Plaintiffs”) for themselves and the Settlement Class Members (as defined below), on the one hand, and DIRECTV, LLC (“DIRECTV” or “Defendant”), on the other hand. Plaintiffs and Defendant are referred to collectively in this Settlement Agreement as the “Parties.”

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • October 24th, 2018

($1,800,000.00) and provide one or more declarations in support of the Settlement, acknowledging and stipulating that the remedial measures has or will include:

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • April 20th, 2018

This Class Action Settlement Agreement and Release (“Agreement”) is submitted pursuant to California Code of Civil Procedure section 382. Subject to the approval of the Court, this Agreement memorializes the settlement between and among all Parties to fully resolve the Action and associated claims. This Agreement is entered into by and between Plaintiffs David and Ramona Guerra; Michael Cusanelli and Feng Yu Hsiao; Charlie and Christine Hebert; Edward Eugene Snyder III and Judy Ann Snyder as Trustees of the Snyder Family 2008 Revocable Trust; Sean Docherty and Krysia Von Burg; Stephon G. Allen; Sarmad and Anwir Mansour; and Antonio Guzman and Lisa Howard, individually on their own behalf and in their representative capacity on behalf of the Settlement Class (collectively, “Plaintiffs”), and Defendants Centex Homes (“Centex”), Burlingame Industries, Inc. d/b/a Eagle Roofing Products (“Eagle”) and Suntech America, Inc. (“Suntech America”), and Cross-Defendants ASI Liquidating Co., Inc. f

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • February 10th, 2022 • Florida

Plaintiff, Ulysses Holmes ("Plaintiff'),1 individua lly and on behalf of the Settlement Class (defined below), and Defendant, WCA Management Company, L.P. ("WCA") (collectively, the "Parties"), enter into this Class Action Settlement Agreement and Release ("Agreement") to resolve all claims in this action, subject to the approval of the Court.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Class Action Settlement Agreement and Release • January 8th, 2021 • New York

MICHAEL L. FERGUSON,MYRL C. JEFFCOAT and DEBORAH SMITH,individually and as representatives of a class of similarly situated participants and beneficiaries, and on behalf of the DST SYSTEMS, INC. 401(K) PROFITSHARING PLAN, Plaintiffs, v. ROBERT D. GOLDFARB, Defendant. Civil Action No. 1:20-cv-07092

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CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • September 20th, 2017 • Washington

This Class Action Settlement Agreement and Release (“Settlement Agreement” or “Agreement”) is made, subject to Court approval, by and between Defendant Swift Transportation Company of Arizona, LLC, and the representative Plaintiffs: (1) Troy Slack;

AMENDED CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • January 23rd, 2017

Plaintiff KATRINA ALLISON (“Plaintiff” or “Class Representative”), on behalf of herself and all others similarly situated and by and through her counsel, and Defendant LSI Products, Inc. (“LSI” or “Defendant”), by and through its counsel, hereby enter into this Amended Settlement Agreement and Release (“Settlement Agreement”), subject to the approval of the Court. This Settlement Agreement supersedes the Class Action Settlement Agreement and Release dated April 2016, Amended Class Action Settlement Agreement and Release dated September 2016. The Parties, in consideration of the mutual promises, agreements, and covenants contained herein, the sufficiency and receipt of which are hereby acknowledged, stipulate and agree as follows:

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • January 10th, 2024 • Michigan

This Class Action Settlement Agreement and Release, dated October 13, 2023, is made and entered into by and among Plaintiffs, for themselves individually and on behalf of the Settlement Class (as defined below), and Defendant Wright & Filippis, LLC (“Wright & Filippis”). This Settlement Agreement fully and finally resolves and settles all of Plaintiffs’ and the Settlement Class’s Released Claims, upon and subject to the terms and conditions hereof, and subject to the Court’s approval.

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • May 8th, 2022
CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • November 16th, 2023

Plaintiffs Janie Marcaurel, Gabriel Fierro, Shelby Ingram, Mark Krenzer, Mary J. Fusilier, Clifford Harris, Nolan Brodie, Miguel Montelongo, Gerald Davis, Steven Dudley, Edward Couture, Rafael Moran, and Mary Chubbuck (collectively, “Plaintiffs”), on behalf of themselves and all others similarly situated, and Defendant USA Waste-Management Resources, LLC (“WM” or “Defendant”) (collectively, the “Parties”) hereby enter into this Class Action Settlement Agreement and Release (“Settlement Agreement” or “Settlement”), subject to Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. In consideration of the mutual promises, agreements, and covenants contained herein, the sufficiency and receipt of which are hereby acknowledged, the Parties agree as follows:

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • March 30th, 2021 • Washington
CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • April 15th, 2019 • Michigan

This Class Action Settlement Agreement and Release (“Agreement”) is made and entered into as of this 15th day of April, 2019, by Warren Burch, James Bodley, Kyle Matson, and Ronald McCallum (“Plaintiffs”), on behalf of themselves and the Settlement Class, as defined below, and Defendant Whirlpool Corporation (“Whirlpool”), to settle, fully and finally, all of the claims that have been or could have been brought in two putative class-action lawsuits against Whirlpool relating to certain dishwashers described below.

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • August 7th, 2020

THIS SETTLEMENT AGREEMENT AND RELEASE is entered into by and between Plaintiffs L. Zingerman, D.D.S., P.C. d/b/a Niles Family Dental (“Zingerman”), Joshua Iron Wing, and Joshua Rafofsky (Iron Wing and Rafofsky are referred to herein as the “California Plaintiffs”), individually and as representatives of the Settlement Class described herein (collectively “Representative Plaintiffs”), on the one hand, and Defendant, Nissan North America, Inc. (“NNA” or “Nissan” or “Defendant”), on the other hand (Representative Plaintiffs and Nissan are the “Parties”), and is made and entered into pursuant to Rule 23 of the Federal Rules of Civil Procedure and subject to Court approval. Subject to the terms provided herein, this Agreement is intended to forever settle and compromise all claims, disputes and controversies, of any kind or nature whatsoever, whether known or unknown, which were raised or could have been raised, between or among the Parties, which in any way arise out of or relate to the al

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • March 27th, 2005 • California

This Class Action Settlement Agreement and Release (“the Agreement”) is entered into this 1st day of July, 2003 (“the Effective Date”), between Plaintiff Peter Plaintiff, on behalf of himself and all others similarly situated, on the one hand (collectively “Plaintiffs”), and Defendant Defendant Co., its parents, affiliates, successors and assigns on the other.

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • May 15th, 2015 • Arizona

between ETAN GOLDMAN (“GOLDMAN” or “CLASS REPRESENTATIVE”), individually and on behalf of the CLASS he seeks to represent, on the one hand, and LIFELOCK, INC. (“LIFELOCK”), on the other hand, subject to both the terms and conditions hereof and the COURT’s approval.

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • September 20th, 2022 • California
CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • September 4th, 2020 • South Carolina

This Settlement Agreement and Release (“Agreement”) is made and entered into this th day of August 2020, by and among (1) Plaintiff Mark Fitzhenry (“Plaintiff”), individually and on behalf of the Settlement Class, and (2) Defendant Independent Home Products, LLC (“IHP”), subject to preliminary and final approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Plaintiff, Class Counsel, and IHP hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon the Effective Date, all Released Claims, including those claims asserted in the action titled, Mark Fitzhenry v. Independent Home Products, LLC, Case No. 2:19-cv-02993-SAL (D.S.C.) (the “Action”), shall be settled and compromised upon the terms and conditions contained herein.

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • March 11th, 2024 • Pennsylvania

LIVINGSTON, individually, as natural parent and next friend of K.J., a minor; BRADLEY HAIN, individually, as natural parent and next friend of N.H. and T.H., minors; and HAILEY JOWERS, on behalf of themselves and all others similarly situated,

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