Plaintiff’s Release Clause Samples

Plaintiff’s Release. Plaintiff and his or her respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally, release and discharge Released Parties from all claims, transactions, or occurrences that occurred during the Class Period, including, but not limited to: (a) all claims that were, or reasonably could have been, alleged, based on the facts contained, in the Operative Complaint and (b) all PAGA claims that were, or reasonably could have been, alleged based on facts contained in the Operative Complaint, Plaintiff’s PAGA Notice, or ascertained during the Action and released under 6.2, below. (“Plaintiff’s Release.”) Plaintiff’s Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ compensation benefits that arose at any time, or based on occurrences outside the Class Period. Plaintiff acknowledges that Plaintiff may discover facts or law different from, or in addition to, the facts or law that Plaintiff now knows or believes to be true but agrees, nonetheless, that Plaintiff’s Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s discovery of them.

Plaintiff’s Release. Plaintiffs, on behalf of themselves and their former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally release and discharge the Released Parties from all claims, transactions, or occurrences that occurred during the Class Period, including, but not limited to: (a) all claims that were, or could have been, alleged based on the facts contained in the Operative Complaint; and (b) all PAGA claims that were, or could have been, alleged based on facts contained in the PAGA Notice (“Plaintiffs’ Release”). Plaintiffs’ Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ compensation benefits that arose at any time, or based on occurrences outside the Class Period. Plaintiffs acknowledge they may discover facts or law different from, or in addition to, the facts or law Plaintiffs now know or believe to be true but agree Plaintiffs’ Release shall be and remain effective in all respects, notwithstanding such different or additional facts or the discovery of them.

Plaintiff’s Release. Plaintiff and his respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally, release and discharge Released Parties from all claims, transactions, or occurrences, including, but not limited to: (a) all claims that were, or reasonably could have been, alleged, based on the facts contained, in the Operative Complaint and (b) all PAGA claims that were, or reasonably could have been, alleged based on facts contained in the Operative Complaint, Plaintiff’s PAGA Notice. (“Plaintiff’s Release.”) Plaintiff’s Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ compensation benefits that arose at any time, or based on occurrences outside the Class Period. Plaintiff acknowledges that Plaintiff may discover facts or law different from, or in addition to, the facts or law that Plaintiff now knows or believes to be true but agrees, nonetheless, that Plaintiff’s Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s discovery of them.

Plaintiff’s Release. Effective upon receipt of the Settlement Payment by KCC, (i) the Litigation Trust Plaintiff, including the Litigation Trustee, on behalf of themselves, the Tribune Debtors and the Tribune Debtors’ estates, (ii) the Note Holder Plaintiffs on behalf of themselves, and on behalf of the holders of Senior Notes or PHONES Notes for whom they act as Successor Indenture Trustee, (iii) the Retiree Plaintiffs on behalf of themselves, and (iv) each of their respective assigns, attorneys, insurers, beneficiaries, employees, officers, directors, shareholders, direct and indirect parents, subsidiaries, parties, affiliates, partners, legal and equitable owners, members, predecessors in interest, successors in interest, representatives, spouses, heirs, executors, and administrators solely in their capacity as such that the Litigation Trust Plaintiff, the Note Holder Plaintiffs, or the Retiree Plaintiffs have the ability to bind, hereby release and forever discharge Defendant, its respective predecessors, successors, heirs, executors, administrators, and assigns, all of their past and present, direct and indirect parents, subsidiaries, affiliates, shareholders, members, partners, legal and equitable owners, and all of their respective past and present attorneys, accountants, insurers, beneficiaries, employees, officers, directors, managers, trustees, and representatives, solely in their capacity as such (collectively the “Defendant Released Parties”) from any and all present, past, or future claims, demands, debts, losses, offsets, obligations, warranties, costs, expenses, rights of action, and causes of action of every kind and nature whatsoever, whether based on contract, tort, statutory, or other legal or equitable theory of recovery, whether known or unknown, suspected or unsuspected, existing, or claimed to exist, and whether arising in the past or future, seeking recovery of Defendant’s Shareholder Transfers, or seeking damages on account of or other relief specifically associated with Defendant’s Shareholder Transfers, including claims for a constructive trust, post-petition interest and/or prejudgment interest (collectively the “Plaintiffs’ Released Claims”). The foregoing release does not include, inter alia, the matters set forth in Paragraph 4.d or claims or rights arising out of or seeking to enforce this Agreement.

Plaintiff’s Release. Plaintiffs and their respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally, release and discharge Released Parties from all claims, transactions, occurrences, liabilities, costs and expenses (inclusive of attorneys’ fees), that occurred during the Class Period including, but not limited to: (a) all claims that were, or reasonably could have been, alleged based on the facts stated in the Operative Complaint, or in the prior iterations thereof, including, without limitation, any and all claims involving any alleged failure to pay minimum wage, overtime compensation, and for all hours worked, failure to pay wages twice in a calendar month, failure to furnish accurate itemized wage statements, failure to pay all wages at termination or separation from employment, claims of unlawful rounding of hours worked, claims for off-the-clock work, wage statement penalties, waiting time penalties, PAGA penalties, failure to reimburse business expenses, and the California Unfair Competition Law, Cal. Bus. & Prof Code § 17200 et seq.; (b) all PAGA claims that were, or reasonably could have been, alleged based on facts contained in the Operative Complaint, or prior iterations thereof, the PAGA Notice, or (c) ascertained during the Action and released under 6.2, below (“Plaintiffs’ Release”). Plaintiffs’ Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ compensation benefits that arose at any time, or based on occurrences outside the Class Period. Plaintiffs agree that by signing this Agreement they become bound by the terms herein stated and further agree not to request to be excluded from the Participating Class Members and agree not to object to any of the terms of this Agreement. Non-compliance by the Plaintiffs with this paragraph shall be void and of no force or effect. Any request by Plaintiffs for exclusion or objection shall therefore be void and of no force or effect. Plaintiffs acknowledge that Plaintiffs may discover facts or law different from, or in addition to, the facts or law that Plaintiffs now know or believe to be true but agree, nonetheless, that Plaintiffs’ Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiffs’ discovery of them.

Plaintiff’s Release. In exchange for a payment of $5,000, Plaintiff and each of her former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally, release and discharge Released Parties from all claims, transactions, or occurrences, whether known or unknown, under federal, state, or local law, against Defendant and all Released Parties through the date this Settlement is signed by Plaintiff (“Plaintiff’s Release”). This includes, but is not limited to, all claims arising from or based on Plaintiff’s employment with Defendant or separation therefrom, as well as any claims attributable to: common law; contract, quasi-contract or tort; unpaid salary, compensation or benefits; the Employee Retirement Income Security Act of 1974, as amended; the Internal Revenue Code of 1986, as amended; harassment, discrimination or retaliation under Title VII of the Civil Rights Act of 1964, the Civil Rights Act of 1991, the Americans With Disabilities Act, Section 1981 of the Civil Rights Act of 1866; the Federal Medical Leave Act; the laws of California; the California Labor, Government and/or Business and Professions Codes including but not limited to California Fair Employment and Housing Act, the California Family Rights Act and the California Unfair Business Practices Act; the California Constitution; the DocuSign Envelope ID: CFA6DA4E-A8A6-4D5B-9EE3-3F29BF7E061B California Consumer Credit Reporting Agencies Act; any federal, state, or local employment, discrimination, harassment or retaliation law, regulation or ordinance relating to employment or separation from employment. This general release also includes the claims released by Participating Class Members under section 5.2 below. Plaintiff’s Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, or workers’ compensation benefits that arose at any time. Plaintiff acknowledges that Plaintiff may discover facts or law different from, or in addition to, the facts or law that Plaintiff now knows or believes to be true but agree, nonetheless, that Plaintiff’s Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s discovery of them.

Plaintiff’s Release. Plaintiffs and their respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally, release and discharge Released Parties from all known and unknown claims, transactions, or occurrences under federal, state and/or local law, statute, ordinance, regulation, common law, or other source of law, including but not limited to claims arising from or related to their respective employments Defendant and their compensation while so employed (“Plaintiffs’ Release”). Plaintiffs’ Release includes, but is not limited to, all claims asserted in, arising from, or related to the Actions, as amended, including all claims that have been alleged or that could have been alleged in the Operative Complaint. Plaintiffs’ Release includes all claims for unpaid wages, including, but not limited to, failure to pay minimum wages, straight time compensation, overtime compensation, double-time compensation, and interest; the calculation of the regular rate of pay; failure to pay wages at least twice each calendar month; failure to timely pay wages; wages related to time rounding and timekeeping; non-compliant (e.g., missed, short, late, and/or interrupted) meal periods and rest periods; failure to provide meal periods; failure to authorize and permit rest periods; the calculation and payment of meal period and rest period premiums; failure to reimburse business expenses; payment for all hours worked, including off-the-clock work and rounded work time; wage statements and paystubs, including wage statements and paystubs furnished or available in physical, electronic, or other forms; unlawful deductions and/or withholdings from wages; failure to keep accurate records; failure to provide employment records, unlawful background check disclosures; unfair business practices; penalties, including, but not limited to, recordkeeping penalties, wage statement penalties, minimum-wage penalties, waiting-time penalties, statutory penalties and civil penalties; and attorneys’ fees and costs. Plaintiffs’ Release includes all claims arising under the California Labor Code (including, but not limited to, sections 200, 201, 201.1, 201.3, 201.5, 201.8, 202, 203, 204, 205.5, 206, 210, 216, 218, 218.5, 218.6, 221, 222, 222.5, 223, 224, 225, 225.5, 226, 226.2, 226.3, 226.7, 226.8, 227.3, 246, 247.5, 248.5, 256, 432, 450, 510, 511, 512, 515, 516, 550, 551, 552, 558, 558.1, 1174, 1174.5, 1175, 1182.12, 1194, 1194.2, 1194.3, 1197, 1197.1, 1...

Plaintiff’s Release. On the Effective Day of this Agreement, and in consideration of the Settlement Amount and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged by Plaintiff and Class Counsel, Plaintiff, for herself, her successors, heirs, executors, representatives, administrators, bankruptcy trustees, guardians, wards, agents and assigns, and all those who claim through them or who assert claims on their behalf, hereby remise, release, waive, acquit, satisfy, and forever discharges Umpqua, and Umpqua’s past, present, and future officers, directors, heirs, agents, employees, legal representatives, assigns, successors, affiliates, shareholders, beneficiaries, predecessors, insurers, administrators, and successors in interest, Umpqua’s parent, holding, subsidiary, affiliates, and related entities, any business entity or division owning or controlling Umpqua in whole or in part, and any business entity or division owned or controlled in whole or in part by Umpqua (hereinafter collectively referred to as the “Released Parties”), all past, present, and future claims, actions, demands, causes of action, suits, debts, obligations, damages, rights or liabilities, of any nature and description whatsoever, known or unknown, existing or potential, recognized now or hereafter, expected or unexpected, pursuant to any theory of recovery (including, but not limited to, those based in contract or tort, common law or equity federal, state, or local law, statute, ordinance, or regulation, and for claims for compensatory, consequential, punitive or exemplary damages, statutory damages, penalties, interest, attorney’s fees, costs, or disbursements against the Released Parties (collectively “Plaintiff’s Released Claims”), which the Plaintiff ever had, now has, or which any personal representative, successor, heir, or assign of the Plaintiff hereafter can, shall or may have against the Released Parties, for, upon, or by reason of any matter, cause, or thing whatsoever, from the beginning of the world to the Effective Date of this Agreement, relating to or arising out of in any way the relationship with, or prospective relationship with, or contact otherwise with Umpqua. The Released Claims include any type of relief that can be released as a matter of law, including, without limitation, claims for wages, damages, unpaid costs, penalties (including civil and waiting time penalties), liquidated damages, punitive damages, interest, attorneys’ fees...

Plaintiff’s Release. Plaintiff and his respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally, release and discharge Released Parties from all claims, transactions, or occurrences arising from or under his employment with Defendant, including, all claims that were, or reasonably could have been, alleged, based on the facts contained, in the Operative Complaint or ascertained during the Action and released under 6.2, below. (“Plaintiff’s Release.”) Plaintiff’s Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, or workers’ compensation benefits that arose at any time. Plaintiff acknowledges that Plaintiff may discover facts or law different from, or in addition to, the facts or law that Plaintiff now knows or believes to be true but agrees, nonetheless, that Plaintiff’s Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s discovery of them.