CLASS ACTION SETTLEMENT AGREEMENT AND RELEASEClass Action Settlement Agreement • April 7th, 2023 • Maryland
This Class Action Settlement Agreement and Release (“Settlement Agreement”) is entered into by and among the following parties: (i) James and Kuru Smith and Keisha Grant, individually and on behalf of the putative Settlement Class (as defined below) (the “Plaintiffs”), and (ii) Defendants Oliveri & Associates, LLC and John Oliveri, Esq. (“Defendants”) (Plaintiffs and Defendants shall be referred to collectively as the “Parties,” individually as a “Party”) as of April 6, 2023. This Settlement Agreement is conditioned upon and subject to approval of the Court as required by Rule 23 of the Federal Rules of Civil Procedure. The Parties hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Settlement Agreement, the Litigation (as defined below) and all Released Claims (as defined below) shall be finally and fully settled, compromised, and released, on the following terms and conditions: