Defendant’s Denials. Defendant denies (1) all the material allegations in this 17 Action, (2) that Defendant violated the FCRA or any other law, (3) that Defendant is liable for damages, 18 penalties, interest, restitution, attorneys’ fees, or costs, or for any other remedy on account of the claims 19 asserted in the Action, and (4) that class certification is appropriate as to any claim in the Action. 20 Defendant contends that its policies, procedures, and practices comply with the FCRA and all other 21 applicable laws. Defendant has agreed to settle the Action solely to avoid the burden, expense, and
Defendant’s Denials. Defendant denies (1) all the material allegations in this 28 Action, (2) that Defendant violated any applicable laws, (3) that Defendant is liable for damages, 1 penalties, interest, restitution, attorneys’ fees, or costs, or for any other remedy sought in the Action, and
Defendant’s Denials. Defendant denies (1) all the material allegations in this Action, (2) 3 that Defendant violated any applicable laws, (3) that Defendant is liable for wages, damages, penalties, 4 interest, restitution, attorneys’ fees, or costs, or for any other remedy on account of the claims asserted in 5 the Action, and (4) that class action certification is appropriate as to any claim in the Action. Defendant 6 contends that its policies, procedures, and practices comply with all laws asserted in the Action. The 7 Parties agree that the Agreement is a compromise and settlement of potential and/or disputed claims, and 8 that the Agreement, nor any action taken to carry out the Agreement, may not be construed or used as an 9 admission or concession of, or constitute a finding of, liability, fault, wrongdoing, or culpability of any 10 kind. Defendant has agreed to settle the Action solely to avoid the burden, expense, and uncertainty of 11 litigation. Any statements in this Agreement are made for settlement purposes only.
Defendant’s Denials. Defendant denies any liability under the FCRA and denies 18 that class certification is appropriate in this Action. Defendant further denies that it engaged in any non- 19 willful or willful violation of the FCRA. As part of the Agreement, Defendant specifically denies that it 20 engaged in any wrongdoing, denies the allegations in the Complaint, denies that Defendant is liable for 21 damages, penalties, interest, restitution, attorneys’ fees or costs or any other remedy, and denies that any 22 claim asserted by Plaintiff Xxxxxx is suitable for class treatment other than for settlement purposes. The 23 Agreement is not and shall not in any way be deemed to constitute an admission or evidence of any 24 wrongdoing or liability on the part of Defendant, nor of any violation of any federal, state, or municipal 25 statute, regulation, or principle of common law or equity. Defendant has agreed to settle the Action
