Common Contracts

SETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • March 12th, 2021 • California

• Contract Type
  Settlement Agreement
• Filed
  March 12th, 2021
• Jurisdiction
  California

This Settlement Agreement and Release (“Agreement”), dated as of June 18, 2019, is entered into by Plaintiffs, James Walters, Michelle Dixon, Charles Powell, and Deana Polcare (Plaintiffs Dixon, Powell, and Polcare will be referred to as “Minnesota Plaintiffs” and collectively with Plaintiff Walters, they shall be referred to as “Plaintiffs”) individually and on behalf of the Settlement Class defined herein, and Defendant Target Corporation (“Target”). Plaintiffs and Target are each individually a “Party” and are collectively the “Parties.” The Parties hereby agree to the following terms in full settlement of the actions entitled Walters v. Target Corp., No. 3:16-cv-1678-L-MDD (S.D. Cal.) (“California Action”) and Dixon, et al. v. Target Corp., No. 0:18-cv-02660 (D. Minn.) (“Minnesota Action”) (California Action and Minnesota Action collectively, the “Actions”), subject to Final Approval, as defined below, by the United States District Court for the Southern District of California (“Co