Consideration and Release of Claims. In consideration for Defendant’s payment of the Settlement Amount as set forth in this Settlement Agreement, upon the Final Approval Date (and except as to such rights or claims as may be created by this Settlement Agreement) the Named Plaintiffs and all Class Members, shall fully, finally, and forever release, settle, compromise, relinquish, and discharge any and all of the Released Parties from any and all claims, debts, penalties, liabilities, demands, obligations, guarantees, costs, expenses, attorneys’ fees, damages, losses, fines, liens, interest, restitution, actions, or causes of action of whatever kind or nature that were alleged in the Action or could have been alleged in the Action arising out of the facts or circumstances alleged in the Action during the Class Period, and including federal, state, and municipal claims during the Class Period. The claims released by the Class Members include but are not limited to all claims accrued during the Class Period for the following: any claims for failure to pay minimum wages or overtime wages, or otherwise for failing to pay for all time worked, under the federal Fair Labor Standards Act (“FLSA”) and applicable state and municipal law (including common law, statutes, ordinances, and regulations); any claims for failures to keep or furnish proper employment records under the FLSA or under applicable state and municipal law; any claims for failure to make full and timely payment of wages, paid sick leave, business expenses, tips, or service charges under such laws; any claims for failure to provide meal or rest breaks under such laws; any claims related to any of the foregoing for liquidated, exemplary, or punitive damages or penalties; any claims related to any of the foregoing for equitable relief (including injunctive or declaratory relief); and any claims related to any of the foregoing for prejudgment interest and attorneys’ fees and costs. The Class Members likewise covenant not to xxx the Released Parties with respect to any of the claims the Class Members have released that accrued during the Class Period.
Consideration and Release of Claims. In consideration for Defendant’s payment of the Settlement Amount as set forth in this Settlement Agreement, upon the Settlement Effective Date the Named Plaintiff and all Participating Settlement Class Members, shall fully, finally, and forever release, settle, compromise, relinquish and discharge any and all of the Released Parties for any acts that are either alleged in the Action or could have been alleged in the Action based on the facts set forth in the Action, including, without limitation, any claims for compensatory or exemplary damages, owed wages or reimbursement, restitution, losses, penalties, fines, liens, attorneys’ fees, costs, expenses, debts, interest, equitable relief (including injunctive or declaratory relief), charge backs, or liquidated damages during the Settlement Class Period.
Consideration and Release of Claims. In consideration for Defendants’ payment of the Settlement Amount, upon the Final Approval Date (and except as to such rights or claims as may be created by this Settlement Agreement) the Named Plaintiffs and all Participating Settlement Class Members fully, finally, and forever release, settle, compromise, relinquish, and discharge any and all of the Released Parties from any and all claims, causes of action, debts, penalties, liabilities, demands, obligations, guarantees, costs, expenses, attorneys’ fees, damages, liquidated or exemplary damages, punitive damages, losses, fines, liens, interest, restitution or other equitable relief, actions, omissions, or causes of action of whatever kind or nature, whether known or unknown, that were alleged in the Action or that could have been alleged in the Action arising out of the facts or circumstances alleged in the Action from the beginning of time through the Final Approval Date, including federal, tribal, state, and municipal claims based on common law, contract, statutes, ordinances, or regulations, lawsuits, administrative actions, arbitrations, and participation to any extent in any pending or future class, collective, or representative actions, or other action of any kind based on or related in any way to the allegations in the Complaint, including but not limited to, for alleged violations of RCW Chapters 39.12 49.12, 49.28, 49.46, 49.48, and 49.52; WAC Chapters 296-126, 296-127, and 296-128; Seattle Municipal Code Chapters 14.19 and 14.20; and all parallel obligations under federal, tribal, state, and local law. The foregoing release by Participating Settlement Class Members excludes claims that are not reasonably related to the claims or allegations asserted in the Action, including claims for discrimination, retaliation, wrongful termination, unemployment, workers’ compensation, and any claims that may not be lawfully released under this Settlement Agreement with Court approval. Further and in addition to the release above, upon the Final Approval Date (and except as to such rights or claims as may be created by this Settlement Agreement), Plaintiffs hereby release all Released Parties, from any and all claims, causes of action, debts, penalties, liabilities, demands, obligations, guarantees, costs, expenses, attorneys’ fees, damages, liquidated or exemplary damages, punitive damages, losses, fines, liens, interest, restitution or other equitable relief, actions, or causes of action of whatever kind o...
Consideration and Release of Claims
