Plaintiff. Davia is an individual residing in the State of California who seeks to promote awareness of exposure to toxic chemicals and improve human health by reducing or eliminating hazardous substances contained in consumer products.
Plaintiff. “Plaintiff” refers to the Class Representative, Xxxxxx Xxxxxxxxx.
Plaintiff. As of the Effective date, in addition to the releases set forth in Sections III.G.1 and III.G.2 above, Plaintiff hereby fully and finally releases Defendants and the other Released Parties from any and all claims, known or unknown, asserted or that might have been asserted, that she has or might have against Defendants and Released Parties (“Plaintiff’s Released Claims”). Plaintiff’s Released Claims include without limitation breaches of contract, whether written, oral or implied; violations of any public policy; tort claims, including but not limited to intentional infliction of emotional distress and negligent infliction of emotional distress, defamation, misrepresentation, and fraud; retaliation claims; common law claims; any other claims for damages, costs, fees, or other expenses, including attorneys’ fees; and any violations of the following statutes, laws, and regulations: Title VII of the Civil Rights Act of 1964, as amended; the Civil Rights Act of 1991; the Americans with Disabilities Act of 1990, as amended; the Age Discrimination in Employment Act of 1967, as amended; the Older Workers Benefit Protection Act; the Family and Medical Leave Act of 1993, as amended; the Fair Labor Standards Act; the Washington Revised Code, the Washington Administrative Code, and any other federal, state, or local civil employment law, statute, regulation, or ordinance capable of being released by Plaintiff, excluding any claims that cannot be released as a matter of law.
Plaintiff. 3 8. The FTC is an independent agency of the United States Government 4 created by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC 5 Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or 6 affecting commerce.
Plaintiff. Upon the occurrence of the Effective Date, Plaintiff generally, unconditionally, irrevocably and absolutely releases and discharges the Released Parties from any and all claims related in any way to the transactions or occurrences between them to date, to the fullest extent permitted by law, including, but not limited to, Plaintiff hiring by and employment with the Defendant, Plaintiff compensation, wages, or pay of any kind related to the Defendant, and all other losses, liabilities, claims, charges, demands and causes of action, known or unknown, suspected or unsuspected, arising directly or indirectly out of or in any way connected with Plaintiff employment with the Defendant Plaintiff Complete and . Plaintiff Complete and General Release is intended to have the broadest possible application and includes, but is not limited to, any tort, contract, common law, constitutional or other statutory claims, including, but not limited to alleged violations of California state law, the Fair Labor Standards Act, Title VII of the Civil Rights Act of 1964, the Equal Pay Act, the Americans with Disabilities Act, the Employee Retirement Income Security Act, the Americans with Disabilities Act, the Age Discrimination in Employment Act, the Occupational Safety and Health Act, the National Labor Relations Act, the Family and Medical Leave Act, the California Family Rights Act, the California Fair Employment and Housing Act, the California Labor Code, the California Constitution, the California Business and Professions Code, the California Industrial Welfare Commission Wage Orders, the California Government fees, costs and expenses. This release of Plainti Complete and General Release unconditionally, irrevocably and absolutely releases and discharges the Released Parties from any claim that Plaintiff could maintain in any action against any Released Party at the time of the execution of this Settlement Agreement. Notwithstanding the foregoing, this waiver and release of claims does not extend to any rights which as a matter of law cannot be waived and released by private agreement, including rights to sue to enforce this Agreement and rights to unemployment benefits and Plaintiff acknowledges that he may discover facts or law different from, or in addition to the facts or law that he knows or believes to be true with respect to the claims and matters released by way of this Agreement and agrees, nonetheless, that this Agreement and the releases contained in it shall be ...
Plaintiff. Upon entry of final judgment and payment by Defendant of the Gross Settlement Amount in accordance with Section III.E.9 of this Agreement, Plaintiff generally, unconditionally, irrevocably, and absolutely releases and discharges the Released Parties from any and all claims, transactions or occurrences between them that occurred during the Class Period, to the fullest extent permitted by law (“Plaintiff’s Released Claims”). This release of Plaintiff’s Released Claims unconditionally, irrevocably, and absolutely releases and discharges the Released Parties from any claim that Plaintiff could maintain in any action against any Released Party that occurred during the Class Period. Notwithstanding the foregoing, nothing in this Settlement Agreement waives or releases any rights which as a matter of law cannot be waived and released by private agreement, including rights to sue to enforce this Agreement and rights to unemployment benefits and workers’ compensation benefits and claims outside the Class Period. Plaintiff acknowledges he may discover facts or law different from, or in addition to the facts or law that he knows or believes to be true with respect to the claims and matters released by way of this Agreement and agrees this Agreement and the releases contained in it shall be and remain effective in all respects, notwithstanding such different or additional facts or the discovery of them. The Parties declare and represent they intend this Agreement to be complete and not subject to any claim of mistake, the releases herein express full and complete releases, and the releases herein shall be final and complete. The Parties execute this release with the full knowledge that this release of the Plaintiff’s Released Claims cover all possible claims by Plaintiff against the Released Parties, to the fullest extent permitted by law. To the extent permitted by law, Plaintiff expressly waives his right to recovery of any type, including damages, penalties, or reinstatement, in any administrative or court action, whether state or federal, and whether brought by Plaintiff or on Plaintiff’s behalf, related in any way to the matters released herein. Notwithstanding the provisions of section 1542, and for the purpose of implementing a full and complete release and discharge of all of Plaintiff’s Released Claims, Plaintiff expressly acknowledges this settlement is intended to include in its effect, without limitation, all Plaintiff’s Released Claims, which Plaintiff do...
Plaintiff. 8 Xxxxxx is an individual residing in California who seeks to promote awareness of 9 exposures to toxic chemicals and improve human health by reducing or eliminating hazardous 10 substances contained in consumer products.
Plaintiff. The term “Plaintiff” shall refer to Xxxxx Xxxxxxx, in his individual capacity as well as his capacity as representative of a class of persons and entities defined in Paragraph 7 below.
Plaintiff. Plaintiff will enter into an individual settlement agreement, which shall provide for an Individual Settlement Payment, as provided for in this Agreement, and which shall provide for a broad release. This release, waiver and discharge of all claims shall include, but will not be limited to, any and all claims arising out of the Action, as well as additional claims described in the Individual Settlement Agreement
Plaintiff. 16 9. Plaintiff Xxxxxxx Xxxxx is a citizen of California who worked for Defendants within 17 the past year. Throughout Plaintiff’s employment, Plaintiff and Plaintiff’s co-workers were 18 subjected to wage theft.
