Defendant’s Denial of Wrongdoing. Defendant generally and specifically denies any and all liability or wrongdoing of any sort with regard to any of the claims alleged, makes no concessions or admissions of liability of any sort, and contends that for any purpose other than settlement, the Class Action is not appropriate for PAGA or class treatment. Defendant also asserts several defenses to the claims and has denied any wrongdoing or liability arising out of any of the alleged facts or conduct in the Class Action. Neither this Agreement, nor any document referred to or contemplated herein, nor any statements, discussions, or communications, nor any action taken to carry out this Agreement, is or may be construed as, or may be used as an admission, concession, or indication by or against Defendant or any of the Released Parties of any fault, wrongdoing, or liability whatsoever. Nor should the Agreement be construed as an admission that Plaintiffs can serve as adequate Class Representatives. There has been no final determination by any court as to the merits of the claims asserted by Plaintiffs against Defendant or as to whether a class or classes should be certified, other than for settlement purposes only.
Defendant’s Denial of Wrongdoing. Defendant generally and specifically denies any and all liability or wrongdoing of any sort with regard to any of the claims alleged, makes no concessions or admissions of liability of any sort, and contends that for any purpose other than settlement, the Action is not appropriate for class treatment. Defendant asserts a number of defenses to the claims, and has denied any wrongdoing or liability arising out of any of the alleged facts or conduct in the Action. Neither this Agreement, nor any document referred to or contemplated herein, nor any action taken to carry out this Agreement, is or may be construed as, or may be used as an admission, concession, or indication by or against Defendant or any of the Released Parties of any fault, wrongdoing, or liability whatsoever. There has been no final determination by any court as to the merits of the claims asserted by Plaintiffs against Defendant or as to whether a class or classes should be certified, other than for settlement purposes only.
Defendant’s Denial of Wrongdoing. This Settlement Agreement reflects the Parties’ compromise and Settlement of the disputed claims. Its provisions, and all related drafts, communications and discussions, cannot be construed as or deemed to be evidence of an admission or concession of any point of fact or law (including, but not limited to, matters respecting Defendants’ presently pending motions to dismiss or class certification) by any person or entity and cannot be offered or received into evidence or requested in discovery in this Action or any other action or proceeding as evidence of an admission or concession.
Defendant’s Denial of Wrongdoing. Defendant generally and specifically denies any liability or wrongdoing of any kind associated with the claims alleged in the Action and denies that for any purpose other than settlement, the Action is appropriate for class or PAGA treatment. Defendant also asserts several defenses to the claims, and maintains, among other things, that it has complied with Federal and California law in all aspects. Neither this Agreement nor any document referred to or contemplated herein, nor any statements, discussions, or communications, nor any action taken to carry out this Agreement, is or may be construed as, or may be used as an admission, concession, or indication by or against Defendant or any of the Released Parties of any liability, culpability, negligence, or wrongdoing whatsoever. Nor should the Agreement be construed as an admission that Plaintiff can serve as an adequate Class Representative. There has been no final determination by any court as to the merits of the claims asserted by Plaintiff against Defendant or as to whether a class or classes should be certified, other than for settlement purposes only.
Defendant’s Denial of Wrongdoing. Defendant generally and specifically denies any liability or wrongdoing of any kind associated with the claims alleged in the Action and denies that for any purpose other than settlement, the Action is appropriate for class or PAGA treatment. Defendant also asserts several defenses to the claims and has denied any wrongdoing or liability arising out of any of the alleged facts or conduct in the Action. Neither this Agreement nor any document referred to or contemplated herein, nor any statements, discussions, or communications, nor any action taken to carry out this Agreement, is or may be construed as, or may be used as an admission, concession, or indication by or against Defendant or any of the Released Parties of any fault, wrongdoing, or liability whatsoever. Nor should the Agreement be construed as an admission that Plaintiffs can serve as adequate Class Representatives. There has been no final determination by any court as to the merits of the claims asserted by Plaintiffs against Defendant or as to whether a class or classes should be certified, other than for settlement purposes only.
Defendant’s Denial of Wrongdoing. Defendant generally and specifically denies any and all liability or wrongdoing of any sort with regard to any of the claims alleged, make no concessions or admissions of liability of any sort, and contend that for any purpose other than settlement, the Action is not appropriate for class or representative treatment. Defendant asserts several defenses to the claims and has denied any wrongdoing or liability arising out of any of the alleged facts or conduct in the Action. Defendant adopted a comprehensive timekeeping and meal period compliance program many years before the Complaint was filed which includes procedures to (1) encourage employees to report timekeeping and meal or rest period problems and (2) require supervisors and payroll employees to address and correct such problems. This uniquely demonstrates Defendant’s good faith efforts to comply with California wage and hour laws. Neither this Agreement, nor any document referred to or contemplated herein, nor any action taken to carry out this Agreement, is or may be construed as, or may be used as an admission, concession, or indication by or against Defendant or any of the Released Parties of any fault, wrongdoing, or liability whatsoever. Nor should the Agreement be construed as an admission that Plaintiffs can serve as adequate Class Representatives. There has been no determination by any court as to the merits of the claims asserted by Plaintiffs against Defendant or as to whether a class or classes should be certified, other than for settlement purposes only.
Defendant’s Denial of Wrongdoing or Liability Defendants deny all of the claims and contentions that the Plaintiffs allege in the Action and have asserted numerous defenses to liability, class certification, and damages. Defendants do not, by this Settlement Agreement or otherwise, admit any liability of wrongdoing of any kind. Nonetheless, Defendants have taken into account the uncertainty and risks inherent in any litigation, particularly on a class-wide basis, and have concluded that to continue the Action would be protracted and expensive. In light of the above, Defendants have determined that it is desirable and beneficial to them that the Action be fully and finally settled in the manner and upon the terms and conditions set forth in this Settlement Agreement.
Defendant’s Denial of Wrongdoing. Defendants have denied and continue to 25 deny each of the claims and contentions alleged by Named Plaintiff in the Action.
Defendant’s Denial of Wrongdoing. Defendant generally and specifically denies any 2 and all liability or wrongdoing of any sort with regard to any of the claims alleged, makes no 3 concessions or admissions of liability of any sort, and contends that for any purpose other than 4 settlement, the Action is not appropriate for class treatment. Defendant asserts a number of defenses 5 to the claims, and has denied any wrongdoing or liability arising out of any of the alleged facts or 6 conduct in the Action. Neither this Agreement, nor any document referred to or contemplated herein, 7 nor any action taken to carry out this Agreement, is or may be construed as, or may be used as an 8 admission, concession, or indication by or against Defendant or any of the Released Parties of any 9 fault, wrongdoing, or liability whatsoever. There has been no final determination by any court as to 10 the merits of the claims asserted by Plaintiff against Defendant or as to whether a class or classes 11 should be certified, other than for settlement purposes only.
Defendant’s Denial of Wrongdoing. 41. Defendant contends that all of its employees have been compensated in compliance with the law, that their conduct was not willful with respect to any alleged failure to pay any wages, and that it acted in good faith at all relevant times. Defendant has denied and continues to deny each of the claims alleged by Plaintiff in the Action. Defendant denies any wrongdoing or legal liability and believes that it has valid defenses to Plaintiff’s and putative Class Members’ claims. Except for purposes of this Settlement, neither this Agreement nor any action taken to carry out this Settlement, may be in any way used as an admission, concession or indication by or against Defendant of any fault, wrongdoing or liability whatsoever, including any concession that certification of a class other than for the purposes of this Settlement would be appropriate in this or any other case.
