SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • December 13th, 2024
This Settlement Agreement and Release (the “Agreement”) is made by and among Stephan Campbell (“Plaintiff”), on behalf of himself and the Settlement Class (as defined below), on the one hand, and Everything Breaks, Inc. (“Everything Breaks”), on the other hand (collectively, the “Parties”). Plaintiff, Class Counsel (as defined below) and Everything Breaks hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court (as defined below) of a Final Approval Order (as defined below), all Released Claims (as defined below) of Plaintiff and the Settlement Class Members (as defined below) included in the Action (as defined below), shall be settled, compromised and released upon the terms and conditions contained herein.