Participating Class Members’ Release. After the Judgment is final and AHF has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against AHF or related entities for wages based on the Class Period facts and for PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, release Released Parties from (i) all claims that were alleged, or reasonably could have been alleged, based on the Class Period facts stated in the Operative Complaint and ascertained in the course of the Action including: (a) any and all claims involving any alleged failure to pay for all hours worked; (b) any and all claims involving failure to pay minimum wage; (c) any and all claims for failure to reimburse for required business expenses; (d) any and all claims involving any alleged failure to properly provide meal periods and/or authorize and permit rest periods, to pay premiums for missed, late, short or interrupted meal and/or rest periods, or to pay such premiums; (e) any and all claims involving any alleged failure to keep accurate records or to issue proper wage statements to employees; (f) any claim for waiting time penalties under Labor Code section 203; and (g) any and all claims for unfair business practices in violation of Business and Professions Code sections 17200, et seq; and (h) any and all claims under PAGA for civil penalties premised on the facts alleged in Plaintiff’s operative complaint. Except as set forth in Section 6.1 and 6.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.
Participating Class Members’ Release. After the Judgment is final and Ambitions has fully funded the Gross Settlement (and separately paid all employer payroll taxes), Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Ambitions or related entities for wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will release Ambitions and each of its former and present directors, officers, shareholders, owners, attorneys, insurers, predecessors, successors, assigns, and affiliates (“Released Parties”) from the following claims: DocuSign Envelope ID: AC9F757F-60E8-4E69-A505-9939CD2B121B [A]ny and all claims, damages, or causes of action alleged in, or arising out of, the allegations in the Consolidated Complaint (as defined below) in the Action that arose during the Class Period and which were alleged, or could have been alleged, by Plaintiffs based on any of the factual allegations contained in the Consolidated Complaint in the Action, including, but not limited to, claims under state, federal (i.e., Fair Labor Standards Act (“FLSA”)) or local law including, but not limited to claims for unpaid minimum and overtime wages (including, inter alia, in connection with off-the-clock work and improper rounding of time), claims related to non-compliant meal and rest breaks or periods and nonpayment of premium pay for such, failure to comply with itemized employee wage statement provisions, failure to pay wages due at separation and associated waiting time penalties, failure to timely pay wages during employment, failure to maintain compliant time and payroll records, the failure to reimburse for business expenses, and unfair or unlawful business practices pursuant to California Business and Professions Code § 17200, et seq. based on the aforementioned. The Released Class Claims specifically include, but are not limited to, all claims arising under California Labor Code sections 201, 202, 203, 204, 210, 218.5, 226, 226.7, 510, 512, 558, 558.1, 1174, 1174.5, 1194, 1194.2, 1197, 1197.1, 1198, 2800 and 2802, California Industrial Welfare Commission Wage Order 5-2001, California Business and Profession Code sections 17200, et seq., California Code of Civil Procedure s...
Participating Class Members’ Release. After the Judgment is final and Defendant has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against or related entities for wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, release Released Parties from (i) all claims that were alleged, or reasonably could have been alleged, based on the Class Period facts stated in the Operative Complaint. Except as set forth in Section 6.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.
Participating Class Members’ Release. After the Judgment is final and Electro Adapter has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Electro Adapter or related entities for wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, release Released Parties from (i) all claims that were alleged, or reasonably could have been alleged, based on the Class Period facts stated in the Operative Complaint including the (1) failure to pay overtime wages; (2) failure to pay minimum wages; (3) failure to provide meal periods or provide premium wages in lieu thereof; (4) failure to provide rest periods or provide premium wages in lieu thereof; (5) wage statement violations under Labor Code section 226, et seq.; (6) failure to timely pay all wages due at separation; (7) unfair business practices in violation of Business and Professions Code section 17200, et seq. premised on the above claims; and violation of or liability under California Labor Code under sections 201, 202, 203, 204, 218.5, 218.6, 226, 226.3, 226.7, 510, 512, 516, 558, 1194, 1197, 1198, and the relevant Wage Orders issued by the Industrial Welfare Commission, and any and all related claims for attorneys’ fees and costs. Except as set forth in Section 5.3 of the Settlement Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.
Participating Class Members’ Release. After the Judgment is final and Defendants have fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendants or related entities for wages based on the facts alleged in the Action for the duration of the Class Period and PAGA Period, which are resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, release the Released Parties from all claims that were alleged, or reasonably could have been alleged, based on the facts stated in the Operative Complaint, including claims for failure to provide meal and rest breaks, failure to pay for meal and rest break premiums pay in lieu thereof and at the correct rates paid for same, pay overtime wages and the correct rates paid for same, pay minimum or regular wages for all hours worked, pay timely wages during employment, pay all earned and accrued wages to discharged/separated employees, furnish accurate itemized wage statements, maintain required payroll records, and indemnify employees for business expenses, and based on violations of Labor Code sections 200-204, 208, 210, 218.6, 226, 226.2, 226.3, 226.7, 510, 512, 558, 1174, 1174.5, 1194, 1194.2, 1197, 1197.1, 1198, 1198.5, 1199, 2802, or Industrial Welfare Commission Order #4, or Business and Professions Code section 17200, et seq., which are premised on the same allegations, and Cal. Code Regs., tit. 8, section 11090 (the “Released Class Claims”). The operative release period for the Released Class Claims is the Class Period. Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.
Participating Class Members’ Release. After the Judgment is final and MV has paid all funds due under the Settlement, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against MV or related entities for wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, release Released Parties from all causes of action and factual or legal theories arising during the Class Period that were alleged in the Operative Complaint (or LWDA notice) or arise from facts alleged in the Operative Complaint (or LWDA notice), including all damages, penalties, interest and other amounts recoverable under said claims, causes of action or legal theories of relief, including but not limited to claims for failure to provide meal periods, failure to provide rest periods, failure to pay wages earned (including at the proper regular rate), failure to pay overtime, failure to indemnify business expenses, failure to provide accurate wage statements, failure to timely pay all final wages, unfair competition, civil penalties under PAGA, Labor Code sections 201, 202, 203, 204, 510, 512, 226, 226.7, 246, 1194, 1194.2, 2802, and 2699, Business and Professions Code section 17200 et seq., and Wage Order 9.
Participating Class Members’ Release. After the Judgment is final and Defendant has fully funded the Gross Settlement Amount and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement Agreement. This means unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or its related entities for wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by the Settlement Agreement. The Participating Class Members will be bound by the following release:
Participating Class Members’ Release. After the Judgment is final and Defendant has fully funded the Gross Settlement (and separately paid all employer payroll taxes), Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities based on facts as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: Plaintiff and all Participating Class Members will release Defendant and all of its subsidiaries, affiliates, shareholders, members, agents, predecessors, successors, and assigns (the “Released Parties”) from those claims alleged in Plaintiff’s PAGA letter and Operative Complaint, including claims for Defendant’s alleged (1) failure to pay minimum wages (Labor Code sections 1194, 1194.2, 1197, 1197.1); (2) failure to pay overtime (Labor Code sections 510, 1197, 1198); (3) failure to provide complete wage statements (Labor Code section 226); (4) failure to provide compliant meal periods and/or pay missed meal period premiums (Labor Code sections 226.7, 512; IWC Wage Order 5- 2001 section 11); (5) failure to provide compliant rest periods and/or pay missed rest period premiums (Labor Code section 226.7; IWC Wage Order 5-2001 section 12); (6) failure to reimburse business expenses (Labor Code section 2802); (7) failure to pay timely wages (Labor Code sections 204, 210); (8) failure to pay final wages (Labor Code sections 201-203); (9) failure to maintain accurate time records (Labor Code sections 1174, 1174.5); (10) civil penalty claims based on the foregoing under California’s Private Attorney Generals Act (“PAGA”), Labor Code section 2699 et seq.; and (11) unfair competition claims based on the foregoing (Bus. & Prof. Code sections 17200 et seq.), and all primary rights associated with these listed claims. (the “Released Claims”).
Participating Class Members’ Release. All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors and assigns, release Released Parties from all claims that were alleged, or reasonably could have been alleged, based on the Class Period facts stated in the Operative Complaint and which occurred during the Class Period, including, any and all claims involving any alleged failure to pay minimum wages, failure to pay overtime, failure to provide meal periods or additional pay in lieu thereof, failure to provide rest breaks or additional pay in lieu thereof, failure to timely pay wages (including at least minimum wage for all time worked, overtime wages for all overtime hours worked, accrued unused vacation, meal period premium wages, and/or rest period premium wages) upon separation, failure to timely pay wages owed during employment, inaccurate itemized wage statements; and any alleged violation of California Labor Code sections 201, 202, 203, 204, 226, 226.7, 510, 512, 1194, 1194.2, 1197, and 1197.1, the applicable California Industrial Welfare Commission Wage Orders, and all related or corresponding federal laws; and any alleged unfair business practices in violation of California Business and Professions Code § 17200 et seq.; and any claims under California Labor Code Section 2698 et seq. for the foregoing Labor Code violations (the “Released Claims”). Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.
Participating Class Members’ Release. Upon Defendant’s deposit of the Gross Settlement Amount with the Settlement Administrator, Class Members who do not submit a timely and valid request for exclusion will release the Released Parties from the Released Claims.
