Common use of Plaintiff’s Release Clause in Contracts

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, 1197.2, 1198, 1198.5, 2698, et seq., 2699,

Plaintiff’s Release. Plaintiffs Upon the Effective Date, and their respective after Defendant has fully funded the Settlement, and as a condition of receiving any portion of the Class Representative Service Payment, Plaintiff and her former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generallyassigns, shall fully and finally release and discharge the Released Parties from any and all claims, known and unknown claimsunknown, 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 Plaintiff’s employment with Defendant ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ Restaurant, Inc. and their Plaintiff’s compensation while so employed (“Plaintiffs’ Release”)an employee of Defendant. Plaintiffs’ Release includesPlaintiff’s Released Claims include, but is are not limited to, all claims asserted in, arising from, or related to the ActionsAction, as amended, including all claims that have been alleged or that could have been alleged in to include but not limited to the Operative ComplaintReleased PAGA Claims and Released Class Claims. Plaintiffs’ Release includes Plaintiff’s Released Claims include 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 failure to properly calculate the regular rate of paypay and associated claims; failure wages related to pay wages at least twice each calendar monthalleged illegal time rounding; failure to timely pay final wages; wages related to time rounding and timekeeping; non-compliant (e.g.missed/short/late/interrupted meal period, missed, short, laterest period, and/or interrupted) meal periods and rest periodsrecovery period wages/premiums; failure to provide meal periods; failure to authorize and permit rest periods and/or recovery periods; the calculation and payment of meal period and period, rest period, and/or recovery period premiums; failure to reimburse reimbursement for all necessary business expensesexpenses ; payment for all hours worked, including off-the-the- clock work and rounded work timework; failure to provide accurate itemized wage statements and paystubs, including wage statements and paystubs furnished or available in physical, electronic, or other formsstatements; deductions; failure to keep accurate records; 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 and payroll reporting penalties, minimum-wage penalties, and waiting-time penalties, statutory penalties and civil penalties; and attorneys’ fees and costs. Plaintiffs’ Release includes Plaintiff’s Released Claims include 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, 218.6 226, 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, 1197.2, 1198, 1198.52698 et seq., 26982699 et seq., 2699.3 and 2802); all claims arising under: the Wage Orders of the California Industrial Welfare Commission; the California Private Attorneys General Act of 2004 (PAGA); California Business and Professions Code § 17200, et seq; California Code of Civil Procedure § 1021.5; all state and local ordinances related to COVID-19 right of recall; the California common law of contract; the FLSA, 29 U.S.C. §§ 201, et seq.; 29 CFR 778.223; 29 CFR 778.315; federal common law; and the Employee Retirement Income Security Act, 2699,29 U.S.C. §§ 1001, et seq. (ERISA). Plaintiff’s Released Claims also include all claims for lost wages and benefits, emotional distress, retaliation, punitive damages, prejudgment interest, past and future medical expenses, and attorneys’ fees and costs arising under federal, state, or local laws for discrimination, harassment, retaliation, failure to accommodate, failure to engage in a good faith interactive process and wrongful termination, such as, by way of example only, (as amended) 42 U.S.C. § 1981, Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), Labor Code § 1102.5 and the California Fair Employment and Housing Act (FEHA); and the law of contract and tort. This release excludes the release of claims not permitted by law.

Plaintiff’s Release. Upon the Effective Date, and as a condition of receiving any portion of their Class Representative Service Payments, Plaintiffs and their respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally, shall fully and finally release and discharge the Released Parties (which as defined above specifically includes Defendants) from any and all claims, known and unknown claimsunknown, transactions, or occurrences under federal, state and/or local law, statute, ordinance, regulation, common law, or other source of lawlaw (“Plaintiff’s Released Claims”). Plaintiffs’ Released Claims shall be set forth more- fully in the stand-alone settlement agreement and general release of all claims. Plaintiffs’ Released Claims include, including but are not limited to to, all claims arising from or related to their respective employments Defendant and their compensation while so employed (“Plaintiffs’ Release”)the Action, as amended. 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 Released Claims include 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; wages related to alleged illegal time rounding; failure to pay wages at least twice each calendar month; failure to timely pay wages; wages related failure to time rounding and timekeepingtimely pay final wages; non-compliant (e.g.missed/short/late/interrupted meal period, missed, short, laterest period, and/or interrupted) meal periods and rest periodsrecovery period wages/premiums; failure to provide meal periods; failure to authorize and permit rest periods and/or recovery periods; the calculation and payment of meal period and period, rest period, and/or recovery period premiums; failure to reimburse reimbursement for all necessary business expenses, including work- related cell-phone expenses and car mileage for work-related travel; payment for all hours worked, including off-the-clock work and rounded work timework; wage statements and paystubs, including wage statements and paystubs furnished or available in physical, electronic, or other formsstatements; unlawful deductions and/or withholdings from wagesdeductions; failure to keep accurate records; failure to provide employment records, suitable seating; failure to maintain temperature providing reasonable comfort; unlawful background check disclosuresdeductions and/or withholdings from wages; unfair business practices; penalties, including, but not limited to, recordkeeping penalties, wage statement and payroll reporting penalties, minimum-wage penalties, and waiting-time penalties, statutory penalties and civil penalties; and attorneys’ fees and costs. Plaintiffs’ Release includes Released Claims include 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, 205.5204.1, 204.2, 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, 558.1516,558, 1174, 1174.5, 1175, 1182.12, 1194, 1194.2, 1194.3, 1197, 1197.1, 1197.2, 1198, 1198.5, 26982698 et seq., 2699 et seq., 2802, and 2804); all claims arising under: the Wage Orders of the California Industrial Welfare Commission; the California Private Attorneys General Act of 2004 (PAGA); California Business and Professions Code section 17200, et seq.; the California Civil Code, 2699,to include sections 3287, 3336 and 3294; 8 CCR sections 3203, 11070, 11090, 11100; California Code of Civil Procedure section 1021.5; all state and local ordinances related to COVID-19 right of recall; the California common law of contract; the FLSA, 29 U.S.C. section 201, et seq.; 29 CFR 778.223; 29 CFR 778.315; federal common law; and the Employee Retirement Income Security Act, 29 U.S.C. section 1001, et seq. (ERISA). Plaintiffs’ Released Claims also include all claims for lost wages and benefits, emotional distress, retaliation, punitive damages, and attorneys’ fees and costs arising under federal, state, or local laws for discrimination, harassment, retaliation, and wrongful termination, such as, by way of example only, (as amended) 42 U.S.C. section 1981, Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), and the California Fair Employment and Housing Act (FEHA); and the law of contract and tort. This release excludes the release of claims not permitted by law.

Plaintiff’s Release. Plaintiffs As a condition of receiving any portion of the Class Representative Service Payment, Plaintiff and their each of her respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally, release and discharge Released Parties (which as defined above specifically includes ASI) 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 her employment with ASI and their her compensation while so employed (“Plaintiffs’ Plaintiff’s Release”). Plaintiffs’ Plaintiff’s Release includes all claims asserted in the Action and/or arising from or related to the facts and claims alleged in the Action or the PAGA Notice (including any amended PAGA Notice), or that could have been raised in the Action or the PAGA Notice based on the facts and claims alleged. Plaintiff’s 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; wages related to alleged illegal time rounding; failure to pay wages at least twice each calendar month; failure to timely pay wages; wages related failure to time rounding and timekeepingtimely pay final wages; non-compliant (e.g.missed/short/late/ interrupted meal period, missed, short, laterest period, and/or interrupted) meal periods and rest periodsrecovery period wages/premiums; failure to provide meal periods; failure to authorize and permit rest periods and/or recovery periods; the calculation and payment of meal period and period, rest period, failure to pay sick pay, and/or recovery period premiums; failure to reimburse reimbursement for all necessary business expenses; payment for all hours worked, including off-the-clock work and rounded work timework; wage statements and paystubs, including wage statements and paystubs furnished or available in physical, electronic, or other formsstatements; unlawful deductions and/or withholdings from wagesdeductions; failure to keep accurate records; failure to provide employment records, suitable seating; failure to maintain temperature providing reasonable comfort; unlawful background check disclosuresdeductions and/or withholdings from wages; unfair business practices; penalties, including, but not limited to, recordkeeping penalties, wage statement and payroll reporting penalties, minimum-wage penalties, and waiting-time penalties, statutory penalties and civil penalties; and attorneys’ fees and costs. Plaintiffs’ Plaintiff’s 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, 246.5, 247, 247.5, 248.1, 248.2, 248.5, 248.6, 248.7, 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, 1197.2, 1197.5, 1198, 1198.5, 26982698 et seq., 2699 et seq., 2802, and 2804); all claims arising under: the Wage Orders of the California Industrial Welfare Commission; the California Equal Pay Act of 1949; the California Fair Pay Act; the California Private Attorneys General Act of 2004 (PAGA); California Business and Professions Code section 17200, et seq.; the California Civil Code, 2699,to include sections 3287, 3336 and 3294; 8 CCR §§ 3203, 11070, 11090, 11100; California Code of Civil Procedure § 1021.5; California Code of Civil Procedure § 1281.98; all state and local ordinances related to COVID-19 right of recall; the California common law of contract; the Fair Labor Standards Act (“FLSA”), 29 U.S.C. §§ 201, et seq.; 29 CFR 778.223; 29 CFR 778.315; federal common law; and the Employee Retirement Income Security Act, 29 U.S.C. §§ 1001, et seq. (ERISA). Plaintiff’s Release also includes all claims for lost wages and benefits, emotional distress, retaliation, punitive damages, and attorneys’ fees and costs arising under federal, state, or local laws for discrimination, harassment, retaliation, and wrongful termination, such as, by way of example only, (as amended) 42 U.S.C. § 1981, Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), as amended by OWBPA, and the California Fair Employment and Housing Act (FEHA); and the law of contract and tort. This release excludes the release of claims not permitted by law. This release is intended to have the broadest possible application. 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. The specific terms of Plaintiff’s Release will be detailed in a stand-alone individual settlement agreement.