SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • September 26th, 2023 • New York
This Settlement Agreement and Release (“Settlement Agreement” or “Agreement”) is entered into by and between TRACEY OCHE, RAFAEL COLON, and JOHN TAVERAS (“Plaintiffs”), individually and on behalf of Participating Settlement Class Members (as defined in Paragraph 20) (together “Plaintiffs”), and NATIONAL MATH AND SCIENCE INITIATIVE (“Defendant” or “NMSI”) (collectively the “Parties”), subject to preliminary and final approval by the Supreme Court of the State of New York, County of New York (the “Court”) as required by Article 9 of the Civil Practice Law and Rules.