CLASS ACTION AND PAGA SETTLEMENT AGREEMENT AND RELEASE OF CLAIMSClass Action and Paga Settlement Agreement • April 6th, 2025 • California
This Class Action and PAGA Settlement Agreement and Release of Claims (“Agreement”) is made by and between Plaintiffs Cristal Lombera and Jesus Cabrera (“Plaintiffs,” “Plaintiff Lombera,” and “Plaintiff Cabrera”), on behalf of themselves and on behalf of the State of California, all similarly-situated individuals, and all allegedly aggrieved employees, and Defendant Creekside Auto Group dba Capitol Toyota (“Defendant”), subject to the approval of the Court, that the Settlement of the Action (as defined below) shall be effectuated upon and subject to the following terms and conditions to be filed for approval by the Court. Plaintiffs and Defendant collectively are referred to in this Agreement as the “Parties.”