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.
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Plaintiff’s Release. In exchange for a payment of $5,000, Plaintiff and each of her 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 occurrencesoccurrences 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; (b) all PAGA claims that were, or reasonably could have been, alleged based on facts contained in the Operative Complaint, Plaintiff’s PAGA Notice; and (c) all claims arising from his employment with Defendant, separation of employment from Defendant, and any acts that have or could have been asserted in any legal action or proceeding against Defendant, whether known or unknown, arising under any federal, state, or local law, against Defendant and all Released Parties through or statute, including, inter alia, those arising under the date this Settlement is signed by Plaintiff (“Plaintiff’s Release”). This includesCalifornia Labor Code, but is not limited toFair Labor Standards Act, all claims arising from or based on Plaintiff’s employment Americans with Defendant or separation therefromDisabilities Act, 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 Employee Retirement Income Security Act, Section 1981 of the Civil Rights Act of 1866; the Federal Medical Leave National Labor Relations Act; the laws of California; the , California LaborCorporations Code, Government and/or California Business and Professions Codes including but not limited to Code, Orders of the California Industrial Welfare Commission, California Fair Employment and Housing Act, the California Family Rights Act Constitution (all as amended), 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 federallaw of contract and tort, state, or local employment, as well as for discrimination, harassment harassment, retaliation, wrongful termination, lost wages, benefits, other employment compensation, emotional distress, medical expenses, other economic and non-economic damages, attorney fees, and costs, arising on or retaliation law, regulation or ordinance relating to employment or separation from employmentbefore the date on which the Settlement is executed. This general release also includes the claims released by Participating Class Members under section 5.2 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, 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 agreeagrees, 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.
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Plaintiff’s Release. In exchange Except for a payment of $5,000▇▇▇▇▇’▇ Individual Action which is carved out from this release, Plaintiff Plaintiffs and each of her their 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, occurrences whether known or unknown, under federalwhich exist or may exist on her behalf as of the date of this Agreement, state, or local law, against Defendant including but not limited to any and all Released Parties through the date this Settlement is signed by Plaintiff (“Plaintiff’s Release”). This includestort claims, but is not limited tocontract claims, wage claims, wrongful termination claims, disability claims, benefit claims, public policy claims, retaliation claims, statutory claims, personal injury claims, emotional distress claims, invasion of privacy claims, defamation claims, fraud claims, quantum meruit claims, and any and all claims arising from under any federal, state or based on Plaintiffother governmental statute, law, regulation or ordinance, including, but not limited to claims for violation of the Fair Labor Standards Act, the California Labor Code, the Wage Orders of California’s employment Industrial Welfare Commission, other state wage and hour laws, the Americans with Defendant or separation therefromDisabilities Act, as well as any claims attributable to: common law; contractthe Age Discrimination in Employment Act (ADEA), quasi-contract or tort; unpaid salary, compensation or benefits; the Employee Retirement Income Security Act of 1974Act, 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 Act, the Family Medical Leave Act, California’s Whistleblower Protection Act, California Business & Professions Code Section 17200 et seq., 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 and all claims arising under any federal, statestate or other governmental statute, or local employment, discrimination, harassment or retaliation law, regulation or ordinance relating to employment or separation from employmentordinance. This general release also includes the claims released by Participating Class Members under section 5.2 below. Plaintiff’s (“Plaintiffs’ Release.”) Plaintiffs’ Release does not extend to any claims or actions to enforce this Agreement, Agreement or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, or workers’ compensation benefits . Plaintiffs acknowledge that arose at any time. Plaintiff acknowledges that Plaintiff Plaintiffs may discover facts or law different from, or in addition to, the facts or law that Plaintiff Plaintiffs now knows know or believes believe to be true but agree, nonetheless, that Plaintiff’s Plaintiffs’ Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s Plaintiffs’ discovery of them.
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Plaintiff’s Release. In exchange for a payment of $5,000, Plaintiff and each of her his former and present spouses, family members, 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 occurrences from the beginning of time through the date Plaintiff signs this Settlement is signed by Plaintiff (“Plaintiff’s Release”). This includesAgreement, including, 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 benefitsunder the California Labor Code; the Employee Retirement Income Security Act of 1974, as amendedCalifornia Fair Employment and Housing Act; the Internal Revenue Code of 1986, as amendedCalifornia Family Rights Act; harassment, discrimination or retaliation under the California Government Code; the California Civil Code; the California Constitution; any Industrial Welfare Commission Wage Order; the Americans with Disabilities Act; 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; 42 U.S.C. § 1981; the Federal Medical Leave Age Discrimination in Employment 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 Labor Standards Act; the California ConstitutionEqual Pay Act; the DocuSign Envelope ID: CFA6DA4E-A8A6-4D5B-9EE3-3F29BF7E061B California Consumer Credit Reporting Agencies ActRehabilitation Act of 1973; the Family and Medical Leave Act (all as amended); all other federal, state, and local statutes, ordinances, regulations, rules, and other laws; all other claims based on constitutional, statutory, common law, or regulatory grounds; all claims based on theories of wrongful or constructive discharge, breach of contract or implied contract, fraud, misrepresentation, promissory estoppel, intentional and/or negligent infliction of emotional distress; and all claims for damages under any federal, state, or local employmentstatutes, discriminationordinances, harassment regulations, rules, or retaliation lawlaws (“Plaintiff’s Release”). Plaintiff’s Release is for any and all relief, regulation or ordinance relating no matter how denominated, including but not limited to employment or separation from employment. This general release also includes the claims released by Participating Class Members under section 5.2 belowback pay, front pay, vacation pay, bonuses, compensatory damages, tortious damages, liquidated damages, punitive damages, damages for pain and suffering, and attorneys’ fees and costs. Plaintiff’s Release does not extend to any claims or actions to enforce this Agreement, or to any claims or actions that cannot be released as a matter of law, including claims for vested benefits, unemployment benefits, disability benefits, social security benefits, or workers’ compensation benefits that arose at any timebenefits. 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 agreeagrees, 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.
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Plaintiff’s Release. In exchange for a payment addition to the release of $5,000Released Class Claims and Released PAGA Claims against the Released Parties made by all Participating Class Members and Aggrieved Employees, Plaintiff and each of her former and present spousesas set forth above, representativesPlaintiff, agentsin his individual capacity, attorneys, heirs, administrators, successors, and assigns generally, agrees to release and discharge the Released Parties from any and all claims, transactionsknown and unknown, under federal, state and/or local law, statute, ordinance, regulation, common law, or occurrencesother source of law, whether known arising as of the date of execution of this Agreement including but not limited to claims arising from or unknownrelated to his employment with Defendant and his compensation while an employee of Defendant (“Plaintiff’s Released Claims”). Plaintiff’s Released Claims include, but are not limited to, all of the Released Claims and any other claims arising under the California Labor Code; any claim arising out of the California common law of contract; the Fair Labor Standards Act, 29 U.S.C. § 201 et seq., and federal common law; all claims for lost wages and benefits, emotional distress, retaliation, punitive damages, and attorneys’ fees and costs arising under federal, state, or local lawlaws for discrimination, against Defendant harassment, and all Released Parties through the date this Settlement is signed by Plaintiff (“Plaintiff’s Release”). This includeswrongful termination, including but is not limited to, all claims arising from or based on Plaintiff’s employment with Defendant or separation therefrom42 U.S.C. section 1981, 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 with Disabilities Act, Section 1981 of the Civil Rights Act of 1866; Age Discrimination in Employment Act, 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 Labor Code, 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 employmentlaw of contract and tort. This general release also includes excludes the release of claims released not permitted by Participating Class Members under section 5.2 belowlaw. Plaintiff’s Release Released Claims 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, 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 agreeagrees, nonetheless, that Plaintiff’s Release Released Claims shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s discovery of them.
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Plaintiff’s Release. In exchange for a payment of $5,000, Plaintiff and each of 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, occurrences whether known or unknown, under federalwhich exist or may exist on her behalf as of the date of this Agreement, state, or local law, against Defendant including but not limited to any and all Released Parties through the date this Settlement is signed by Plaintiff (“Plaintiff’s Release”). This includestort claims, but is not limited tocontract claims, wage claims, wrongful termination claims, disability claims, benefit claims, public policy claims, retaliation claims, statutory claims, personal injury claims, emotional distress claims, invasion of privacy claims, defamation claims, fraud claims, quantum meruit claims, and any and all claims arising from under any federal, state or based on Plaintiffother governmental statute, law, regulation or ordinance, including, but not limited to claims for violation of the Fair Labor Standards Act, the California Labor Code, the Wage Orders of California’s employment Industrial Welfare Commission, other state wage and hour laws, the Americans with Defendant or separation therefromDisabilities Act, as well as any claims attributable to: common law; contractthe Age Discrimination in Employment Act (ADEA), quasi-contract or tort; unpaid salary, compensation or benefits; the Employee Retirement Income Security Act of 1974Act, 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 Act, the Family Medical Leave Act, California’s Whistleblower Protection Act, California Business & Professions Code Section 17200 et seq., 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 and all claims arising under any federal, statestate or other governmental statute, or local employment, discrimination, harassment or retaliation law, regulation or ordinance relating to employment or separation from employmentordinance. This general release also includes the claims released by Participating Class Members under section 5.2 below. (“Plaintiff’s Release.”) Plaintiff’s Release does not extend to any claims or actions to enforce this Agreement, 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 agreeagrees, 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.
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