Joint Stipulation of Class Action Settlement and Release Agreement Sample Contracts

JOINT STIPULATION OF CLASS ACTION SETTLEMENT AND RELEASE AGREEMENT
Joint Stipulation of Class Action Settlement and Release Agreement • December 20th, 2018 • California

Subject to final approval by the Court, it hereby stipulated by and between Plaintiffs Michael Caufield and Henry Hernandez, on behalf of themselves, all others similarly situated and aggrieved, and on behalf of the general public (“Plaintiffs”) and Defendant ITS Logistics, LLC (“Defendant” or “ITS”) that the Action, defined below, is hereby compromised and settled pursuant to the terms and conditions set forth in this Joint Stipulation of Class Action Settlement Agreement (hereinafter “Agreement”) and that the Court shall make and enter judgment, subject to the continuing jurisdiction of the Court as set forth below, and subject to the definitions, recitals, and terms set forth herein which by this reference become an integral part of this Agreement. Plaintiffs and Defendant collectively are referred to in this Agreement as the “Parties.”