Wilson Elser Moskowitz Edelman & Dicker Sample Contracts

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SETTLEMENT AND RELEASE AGREEMENT
Settlement and Release Agreement • February 28th, 2020 • Illinois

This Settlement and Release Agreement (“Agreement” or “Settlement Agreement”) is entered into by and between Royal Die and Stamping LLC d/b/a Royal Power Solutions LLC (“Defendant”), and Francesca Graziano (“Plaintiff”) individually and on behalf of the Settlement Class, in the case of Francesca Graziano v. Royal Die and Stamping LLC d/b/a Royal Power Solutions, LLC, Case No. 2019-L-000169, currently pending in the Circuit Court of the Eighteenth Judicial Circuit, DuPage County Illinois, Law Division. Plaintiff and Defendant is each referred to as a “Party” and are collectively referred to herein as the “Parties.”

SETTLEMENT AND RELEASE AGREEMENT
Settlement and Release Agreement • June 23rd, 2021 • Illinois

This Settlement and Release Agreement (“Agreement,” “Settlement” or “Settlement Agreement”) is entered into by and between Hyatt Corporation (“Defendant”) and Robin Rapai (“Plaintiff”) both individually and on behalf of the Settlement Class, in the case Robin Rapai, individually and on behalf of all others similarly situated v. Hyatt Corporation, Case No. 2017- CH-14483, currently pending in the Circuit Court of Cook County, Illinois, Chancery Division (the “Litigation”). Defendant and Plaintiff are each referred to as a “Party” and are collectively referred to herein as the “Parties.”

PAYMENT IN LIEU OF TAX AGREEMENT
Tax Agreement • August 12th, 2016 • New York

In no event shall the Adjusted PILOT Payment exceed the amount payable if the Facility were subject to taxation and a 485(b) exemption had been granted to eligible portions of the Facility.

PROPOSITION 65 SETTLEMENT AGREEMENT‌
Proposition 65 Settlement Agreement • December 8th, 2023 • California
SETTLEMENT AGREEMENT
Settlement Agreement • April 29th, 2019 • Massachusetts

Subject to final approval by the Court and in exchange for valuable consideration, Plaintiff Rachel Williams (the “Class Representative” or “Plaintiff”) and Defendant American Honda Finance Corporation (“Honda”) enter into this Class Action Settlement Agreement (the “Agreement”) dated April 16, 2019. The Class Representative enters into this Agreement on behalf of herself and the Settlement Class Members as defined below. The Agreement fully and finally compromises and settles this action, which shall be dismissed with prejudice as to all Parties and Released Persons upon the following terms and conditions.

CONCILIATION AGREEMENT / VOLUNTARY COMPLIANCE AGREEMENT
Conciliation Agreement • January 2nd, 2022

A complaint was filed on March 10, 2020, with the United States Department of Housing and Urban Development (“the Department”) alleging that Complainant was injured by

FORBEARANCE AGREEMENT
Forbearance Agreement • December 23rd, 2010 • WPCS International Inc • Communications services, nec

This Forbearance Agreement (“Agreement”) is made as of December 22, 2010, by and among BANK OF AMERICA, N.A. (“Bank”), a national banking association, having an office and place of business located at c/o Special Assets Group, 111 Westminster Street, Mail Sop RI1-102-15-01, Providence, Rhode Island 02903, and WPCS INTERNATIONAL INCORPORATED (“WPCS”), a corporation of the State of Delaware, WPCS INTERNATIONAL – SARASOTA, INC. (formerly Southeastern Communication Services, Inc., herein “Sarasota”) a corporation of the State of Florida, WPCS INTERNATIONAL – ST. LOUIS, INC. (formerly Heinz Corporation, herein “St. Louis”), a corporation of the State of Missouri, WPCS INTERNATIONAL – LAKEWOOD, INC. (formerly Quality Communications & Alarm Company, Inc., herein “Lakewood”), a corporation of the State of New Jersey, WPCS INTERNATIONAL – SUISUN CITY, INC. (formerly Walker Comm Inc., herein “Suisun City”), a corporation of the State of California, WPCS INTERNATIONAL – HARTFORD, INC. (formerly N

SETTLEMENT AGREEMENT
Settlement Agreement • July 23rd, 2021 • California

This Settlement Agreement ( ) is reached by and between Plaintiff Ulisses Lopez , individually and on behalf of all members of the Settlement Class (defined below), on the one hand, and Defendant Good-West Rubber Corp. ( Good-West ), on the other hand. Plaintiff and Defendant are referred to herei

SETTLEMENT AND RELEASE AGREEMENT
Settlement and Release Agreement • March 23rd, 2022 • California
FIRST AMENDED CLASS ACTION SETTLEMENT AGREEMENT AND STIPULATION
Class Action Settlement Agreement and Stipulation • October 29th, 2021 • California

Plaintiff Shelley Marie Brown (“Plaintiff”), on behalf of herself and all others similarly situated, on the one hand, and defendant Alliance Residential Company, LLC (“Defendant”), on the other hand, by and through their respective counsel, in consideration for and subject to the promises, terms, and conditions contained in this First Amended Class Action Settlement Agreement and Stipulation, hereby stipulate and agree, subject to Court approval, as follows:1

CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE
Class Action Settlement Agreement and Release • June 20th, 2023
SETTLEMENT AGREEMENT
Settlement Agreement • September 7th, 2022 • California
SETTLEMENT AGREEMENT
Settlement Agreement • September 11th, 2020 • California
SETTLEMENT AGREEMENT
Settlement Agreement • December 22nd, 2022 • Washington

This Settlement Agreement is made and entered into by and among: (1) Plaintiffs Richard Easter and Tristen Star (“Plaintiffs” or “Class Representatives”), on behalf of themselves and the proposed Settlement Class; and (2) Sound Generations (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.

SETTLEMENT AGREEMENT BETWEEN
Settlement Agreement • October 3rd, 2023 • California

Sara Hammond (“Hammond”) and Bovano Travel Goods, Inc., f/k/a American Union Luggage (herein referred to as “BOVANO”) (Hammond and BOVANO are collectively referred to as the “Parties”), enter into this agreement (“Settlement Agreement”) for the purpose of avoiding prolonged and costly litigation to settle Hammond’s allegations that BOVANO violated Proposition 65. The effective date of this Settlement Agreement shall be the date upon which it is fully executed by all Parties hereto (the “Effective Date”).

SETTLEMENT AGREEMENT
Settlement Agreement • April 22nd, 2020 • California
TIBER CREEK CORPORATION ICO ENGAGEMENT AGREEMENT
Ico Engagement Agreement • August 31st, 2018 • Buying.com LLC

This INITIAL COIN OFFERING ENGAGEMENT AGREEMENT (this “Agreement”) dated June ____, 2018 (the “Effective Date”) is entered into by and between TIBER CREEK CORPORATION (“Tiber Creek”) and Dropshippers.com LLC, together with any successors (collectively “Dropshippers”). Tiber Creek and Dropshippers are sometimes referred to herein individually as a “Party” or collectively as the “Parties.”

SETTLEMENT AGREEMENT
Settlement Agreement • April 18th, 2017 • Missouri

This Settlement Agreement (the “Settlement Agreement”) is made by and between Plaintiffs Michael E. Taylor, Dawn R. Fortner, and Catherine Gemkow (“Plaintiffs”), on behalf of themselves and the Settlement Class (defined below), on the one hand, and Defendants Dynamic Pet Products, LLC and Frick’s Meat Products, Inc. (“Defendants”), on the other hand, subject to and conditioned upon Court approval of the terms and conditions hereof.

SETTLEMENT AGREEMENT AND RELEASE
Settlement Agreement and Release • August 2nd, 2023 • Illinois
CLASS ACTION AND PAGA SETTLEMENT AGREEMENT AND CLASS NOTICE
Class Action and Paga Settlement Agreement and Class Notice • March 7th, 2023 • California

This Class Action and PAGA Settlement Agreement (“Agreement”) is made by and between Plaintiffs Yvette Cosme, Cari Walker, and Flor Alejandra Rodriguez (together “Plaintiffs”) (collectively, “Class Representatives” or “Plaintiffs”), individually and on behalf of all putative class members, putative aggrieved employees, and the State of California, on the one hand, and Defendant Ambitions California, Inc. (“Ambitions”) on the other hand. The Settlement Agreement refers to Plaintiffs and Ambitions collectively as “Parties,” or individually as “Party.” This Settlement Agreement is subject to the terms and conditions set forth below and the Court’s approval. This Settlement Agreement completely resolves the Released Class Claims (as defined herein) and Released PAGA Claims (as defined herein) against the Released Parties (as defined herein).

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