Stipulation of Settlement and Release of Claims Sample Contracts

LAURIN DESSEAUX, individually and on behalf of all similarly situated persons,Plaintiffs, v. AVIACODE, INC., Defendant. Case No. 2:17-cv-01065 STIPULATION OF SETTLEMENT AND RELEASE OF CLAIMS Judge: Honorable Bruce S. Jenkins
Stipulation of Settlement and Release of Claims • February 8th, 2019 • Utah

This Stipulation of Settlement and Release of Claims ("Settlement Agreement") is entered into by and between Plaintiff Laurin Desseaux (sometimes referred to hereinafter as "Named Plaintiff” and/or “Class Representative”), on behalf of himself individually and as representative of the individuals who joined this Action under 29 U.S.C. § 216(b) (collectively referred to as “Opt-In Plaintiffs”) and/or members of the Rule 23 Settlement Class described below (collectively referred to as “Plaintiffs” or "Settlement Class Members"). (Plaintiff and Defendant are collectively referred to as the "Parties.")