Common use of Participating Class Members’ Release Clause in Contracts

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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for any of the claims alleged in the Action arising during the Class Period facts or for any PAGA penalties based on any of the claims alleged in the Action arising during the PAGA Period, as alleged in the Action and resolved by this Settlement. Specifically, the Participating Class Members will be bound by the following release: All claims as pled in the Complaint, and any further amended pleadings as necessary, including claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698, et seq. (“PAGA”) based on the allegations in the operative Complaint, as well as any and all wage and hour claims that were asserted or could have been asserted based on the factual allegations contained in the Complaint, or any amended complaints. This also includes, but is not limited to, any and all claims alleged or that could have been alleged based on the facts of the Complaint or any amended complaint for unpaid wages, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to claims under Labor Code section 2698, et seq., Labor Code sections 201, 202, 203, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, all applicable IWC Wage Orders, and Business and Professions Code section 17200 et seq. and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members of the Settlement Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for any of the claims alleged in the Action arising during based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the 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, spouses, heirs, administrators, successors, and assigns, release Released Parties from all claims as pled that were alleged, or reasonably could have been alleged, through the Class Period, based on the facts stated in the Complaint, Operative Complaint and any further amended pleadings as necessaryascertained in the course of the Action, including but not limited to claims for (1) Failure failure to Pay Minimum Wagespay overtime; (2) Failure failure to Pay Overtime Wagesauthorize and/or permit meal breaks or pay lawful premiums; (3) Failure failure to Provide Meal Periodsauthorize and/or permit rest breaks; (4) Failure failure to Permit Rest Breaksreimburse for business-related expenditures; (5) Failure failure to Reimburse Business Expensesfurnish accurate wage statements; (6) Failure to Provide Accurate Itemized Wage Statementswaiting time penalties; (7) Failure to Pay Wages Timely During Employmentunfair business practices; and (8) Failure to Pay violation of Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all Wages Timely Due Upon Separation of Employment; (9) Violation of applicable IWC Wage Orders, Business and Professions Code and (10) Violation of California Labor Code section 2698, 17200 et seq. (“PAGA”) based on the allegations in the operative Complaint., as well as any and all wage and hour claims that were asserted or which could have been asserted based on the factual allegations contained in the Operative Complaint, or any amended complaints. This also includesthrough the Class Period, including, but is not limited to, any and all claims alleged or that could have been alleged based on the facts of the Complaint or any amended complaint for unpaid wages, economic damages, non-non- economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Code section 2698sections 200, et seq., Labor Code sections 201, 202, 203, 204, 210218.5, 226, 226.7, 246500, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, and all applicable IWC Wage Orders, and Business and Professions Code section 17200 et seq. ., and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ ' fees and costs and interest, through the Class Period. For Plaintiff and the members Except as set forth in paragraph 5.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Settlement Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

Participating Class Members’ Release. After the Judgment is final and Defendant Arjo 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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant Arjo or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the The Participating Class Members will be bound by the following release: All claims as pled in the ComplaintParticipating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and any further amended pleadings as necessaryassigns, including claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay release Released Parties from all Wages Timely Due Upon Separation claims, demands, rights, liabilities, penalties, fees, and causes of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698action arising from, et seq. (“PAGA”) based on the allegations in the operative Complaintor related to, as well as any and all wage and hour claims or that were asserted asserted, or that could have been asserted based on the factual allegations contained Class Period facts stated in the ComplaintOperative Complaint and/or ascertained in the course of the Action, or any amended complaints. This also includes, but is not limited toincluding, any and all claims involving any alleged failure to pay all regular wages, minimum wages, and overtime wages due; failure to properly calculate overtime; failure to provide proper meal and rest periods, and to properly provide premium payment in lieu thereof; failure to provide complete, accurate, or properly formatted wage statements; failure to maintain payroll records; failure to timely pay all wages during employment or at separation of employment; waiting time penalties; failure to properly calculate and pay sick pay; failure to reimburse for business expenses; and unfair business practices that could have been alleged based premised on the facts claims, causes of the Complaint action or any amended complaint legal theories of relief described above. Released claims by all Participating Class Members include all claims for unpaid wages, economic damagesovertime wages, non-economic damages, any other damages, civil or statutory penalties, waiting time penaltiesdamages of any kind, liquidated damagesinterest, attorneys’ fees, costs, injunctive relief, restitution, and all any other associated damages and/or penaltiesequitable relief under California or federal statute, ordinance, regulation, common law, or other source of law, including but not limited to claims under the California Labor Code section 2698Code, et seq., Labor Code sections 201, 202, 203, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, all applicable IWC Wage Orders, and California Business and Professions Code, California Civil Code section 17200 et seqand California Industrial Welfare Commission Wage Orders. and Except as set forth in Section 6.3 of this Agreement, Participating Class Members do not release any and all claims or potential claims other claims, including for lost wages and/or vested benefits, consequential economic damageswrongful termination, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members violation of the Settlement Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the The Participating Class Members will be bound by the following release: All claims as pled in the ComplaintParticipating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and any further amended pleadings as necessaryassigns, including release Released Parties from all claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698that were alleged, et seq. (“PAGA”) or reasonably could have been alleged, based on the allegations Class Period facts stated in the operative Operative Complaint, as well as any and all wage and hour claims that were asserted or could have been asserted based on the factual allegations contained in the Complaintincluding, or any amended complaints. This also includes, but is not limited toe.g., any and all claims involving: (1) any alleged failure to pay wages (including minimum wage); (2) any alleged failure to pay overtime compensation; (3) any alleged failure to provide compliant meal periods, or that could have been compensation in lieu thereof; (4) any alleged based on the facts of the Complaint failure to provide compliant rest breaks, or compensation in lieu thereof; (5) any amended complaint for unpaid wagesalleged failure to provide compliant accurate itemized wage statements; (6) any alleged failure to timely pay wages due upon separation; and (7) any alleged unlawful, economic damagesunfair, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to claims fraudulent business actions or practices under Labor Code section 2698, et seq., Labor Code sections 201, 202, 203, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, all applicable IWC Wage Orders, and Business and Professions Code section 17200 §§ 17200, et seq. and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members of the Settlement Class who do not opt arising out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 Labor Code and Industrial Welfare Commission (“Settlement IWC”) Wage Order violations referenced in the Operative Complaint. Except for the PAGA Release described below, Participating Class Release 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 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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the 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 as pled that were alleged, or reasonably could have been alleged, based on the Class Period facts stated in the ComplaintOperative Complaint including claims for failure to pay minimum wages, failure to pay overtime wages, failure to pay the correct applicable overtime rate, failure to pay all hourly wages including minimum and overtime wages as a result of auto-deductions for meal periods, unlawful and inaccurate recording of time, off-the-clock work, failing to authorize and permit meal breaks (including requiring, suffering, and/or permitting Class Members to work through meal breaks), failure to authorize and permit rest periods, failure to indemnify for necessary business expenses including for mileage and cell phone use, failure to timely pay final wages at termination, failure to properly maintain required records, failure to provide accurate itemized wage statements, unfair and unlawful business practices, and any further amended pleadings as necessaryother claims, including claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698, et seqstatutory and/or civil penalties. (“PAGA”) based on the allegations Except as set forth in the operative Complaint, as well as any and all wage and hour claims that were asserted or could have been asserted based on the factual allegations contained in the Complaint, or any amended complaints. This also includes, but is not limited to, any and all claims alleged or that could have been alleged based on the facts of the Complaint or any amended complaint for unpaid wages, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to claims under Labor Code section 2698, et seq., Labor Code sections 201, 202, 203, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, all applicable IWC Wage Orders, and Business and Professions Code section 17200 et seq. and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members Section 6.3 of the Settlement Agreement, Participating Class who Members do not opt out release any other claims, including claims for vested benefits, wrongful termination, violation of the settlementFair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specificallyall 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 any and all claims involving any allegations that Defendant: failed to pay all wages due (including minimum wages, regular wages, sick pay, vacation, paid time off and overtime wages); failed to provide legally-compliant meal and rest breaks and failed to pay premium pay for missed, late, interrupted or short meal and rest breaks; failed to timely pay all earned wages and compensation; failed to provide timely final pay; failed to provide accurate itemized wage statements; failed to reimburse for necessary business expenses; and engaged in unfair business practices due to the underlying violations at any time during the Class Period. This includes any claims for injunctive relief, declaratory relief, restitution, fraudulent business practices or punitive damages alleged or other damages or penalties or which could have been alleged under the facts, allegations and/or claims pleaded as part of the Action. This further includes any and all other claims under California common law, the Participating Class Members will be bound by California Labor Code including but not limited to the following release: All claims as pled in the ComplaintFair Labor Standards Act, California Industrial Welfare Commission Wage Orders, and any further amended pleadings as necessary, including claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay all Wages Timely Due Upon Separation of Employment; (9) Violation of the California Business and Professions Code and (10) Violation of California Labor Code section 2698, et seq. (“PAGA”) based on the allegations alleged in the operative Complaint, as well as any and all wage and hour claims that were asserted or could have been asserted based on the factual allegations contained in the Complaint, or any amended complaints. This also includes, but is not limited to, any and all claims alleged or that could have been alleged based on under the facts of facts, allegations and/or claims pleaded in the Complaint or any amended complaint for unpaid wages, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to claims under Labor Code section 2698, et seq., Labor Code sections 201, 202, 203, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, all applicable IWC Wage Orders, and Business and Professions Code section 17200 et seqAction. and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members Except as set forth in Section 5.3 of the Settlement Agreement, Participating Class who Members do not opt out release any other claims, including claims for vested benefits, wrongful termination, violation of the settlementFair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

Participating Class Members’ Release. After the Judgment is final and Defendant CTI 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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant CTI or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any PAGA penalties based on any of the claims alleged in the Action arising during the PAGA Periodfacts, as alleged in the Action and resolved by this Settlement. Specifically, the The Participating Class Members will be bound by the following release: All claims as pled in the ComplaintParticipating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and any further amended pleadings as necessaryassigns, including release Released Parties from (i) all claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698that were alleged, et seq. (“PAGA”) or reasonably could have been alleged, based on the allegations Class Period facts stated in the operative ComplaintOperative Complaint and ascertained in the course of the Action, as well as any including, under state law and all wage and hour claims the Wage Orders of DocuSign Envelope ID: 7BF4E2F8-D94D-43CA-A2F0-9AC691A792C6 the California Industrial Welfare Commission, that were asserted or could have been asserted based on the factual allegations contained in the Complaint, or any amended complaints. This also includes, but is not limited to, any and all claims alleged or that which could have been alleged based on the facts of factual allegations in the Class Action Complaint or any amended complaint in the Action, including claims for unpaid wages, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to failure to pay minimum wages, straight time compensation, overtime compensation, double time compensation, and interest; failure to timely pay regular and final wages; wages related to time rounding and timekeeping; missed meal period and rest period wages and premiums; meal period waivers and on-duty meal period waivers; payment for all hours worked, including off-the-clock work and uncompensated work time; wage statements and paystubs, including wage statements and paystubs furnished or available in physical, electronic, or other forms; failure to keep accurate records; deductions; declaratory relief; unfair business practices; penalties, including recordkeeping penalties, wage statement penalties, minimum-wage penalties, and waiting-time penalties; statutory penalties and civil penalties; and attorneys’ fees and costs. Without limiting the foregoing, the Released Claims include those claims arising under California Labor Code section 2698, et seq., Labor Code sections Sections 201, 202, 203, 204, 210206, 218.6, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1194.2, 1197, 1197.1, 1198, 2800, 2802, all applicable IWC 1198 and/or those arising under the Industrial Welfare Commission Wage Orders, and ; California Business and Professions Code section 17200 et seq. .; California Code of Regulations, title 8, Section 11160; the California Civil Code sections 3287, 3289, and 3294; California Code of Civil Procedure section 1021; and any claims under the Fair Labor Standards Act (“FLSA”) [29 U.S.C. §§ 201, et seq.] arising during the Class Period and all claims based on the factual allegations alleged or potential which could have been alleged in the Complaint.5. Participating Class Members do not release any other claims, including claims for lost wages and/or vested benefits, consequential economic damageswrongful termination, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members violation of the Settlement Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

Participating Class Members’ Release. After the Judgment is final and Defendant ECF has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting against the Released Parties any of the claims released under the Settlement. (The “Released Parties” are (i) Defendant ECF, (ii) ECF’s current and former officers, directors, managers, employees, agents, predecessors and successors; and (iii) ECF’s related tax-exempt organization: Friends of Exceptional Children’s Foundation, Xxxxxxxx, Inc., and ERAS Home II.) This means that unless you opted out by validly and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant ECF or related entities the Released Parties for any of the claims alleged in the Action arising during wages, liquidated damages, penalties, interest, or other relief based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the 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 claims as pled in the Complaintthat were alleged, and any further amended pleadings as necessaryor reasonably could have been alleged, including claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698, et seq. (“PAGA”) based on the allegations Class Period facts stated in the operative Operative Complaint, as well as any and all wage and hour claims that were asserted or could have been asserted based on through [the factual allegations contained in date the ComplaintCourt enters Preliminary Approval of the Settlement, or any amended complaints. This also includesunless the Class Period is shortened per Paragraph 8 of the Settlement Agreement], but is not limited toincluding, any and all claims involving any alleged or that could have been alleged based on the facts of the Complaint or any amended complaint for unpaid failure to pay minimum DocuSign Envelope ID: 0E0B08D4-BB08-44AA-BF68-AC18FB6F1172 wages, economic damagesfailure to pay overtime, non-economic damagesfailure 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 other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to claims under Labor Code section 2698, et seq., alleged violation of California Labor Code sections 201, 202, 203, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1194.2, 1197, and 1197.1, 1198, 2800, 2802, all the applicable IWC 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 section § 17200 et seq. .; and any and all claims or potential 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 lost wages and/or vested benefits, consequential economic damageswrongful termination, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members violation of the Settlement Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the 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 as pled that were alleged, or reasonably could have been alleged under state, federal or local law, whether statutory, common law, or administrative law, based on the facts alleged in the operative First Amended Complaint, and any further amended pleadings during the periods of employment as necessarydetailers or independent contractors in California during the Class Period, including claims for (1) Failure allegations of alleged, failure to Pay Minimum Wagespay timely wages; (2) Failure failure to Pay Overtime Wagespay overtime wage; (3) Failure meal period violations; rest period violations; failure to Provide Meal Periodspay meal or rest period premiums; (4) Failure failure to Permit Rest Breaksreimburse expenses; (5) Failure to Reimburse Business Expenseswage statement violations; (6) Failure to Provide Accurate Itemized Wage Statementswaiting time penalties; (7) Failure to Pay Wages Timely During Employmentmisclassification of independent contractors; (8) Failure to Pay all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698civil penalties, et seq. (“including penalties under PAGA”) , based on the allegations in the operative Complaint, as well as any and all wage and hour claims that were asserted or could have been asserted based on the factual allegations contained in the Complaint, or any amended complaints. This also includes, but is not limited to, any and all claims alleged or that could have been alleged based on the facts set forth above; violations of the Complaint or any amended complaint for unpaid wages, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to claims under Labor Code section 2698, et seq., Labor Code sections 201, 202, 203, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, all applicable IWC Wage Orders, and Business and Professions Code section 17200 et seq. and any and all claims or potential based on the allegations set forth above; including, but not limited to, claims for lost wages and/or injunctive relief; penalties of any nature; interest; fees; and costs (“Released Claims”). 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, consequential economic damageswrongful termination, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members violation of the Settlement Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for any of based on the claims facts alleged in the Action arising during for the Class Period facts or for any PAGA penalties based on any of the claims alleged in the Action arising during the PAGA Period, as alleged in the Action and resolved by this Settlement. Specifically, the The Participating Class Members will be bound by the following release: All claims as pled in the ComplaintParticipating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and any further amended pleadings as necessaryassigns, including claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay release and discharge the Released Parties from all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698claims, et seq. (“PAGA”) based on the allegations in the operative Complaint, as well as any and all wage and hour claims that were asserted or could have been asserted based on the factual allegations contained in the Complainttransactions, or any amended complaints. This also includes, but is not limited to, any occurrences that occurred during the Class Period and all claims alleged or that could have been alleged based on the facts of the Complaint or any amended complaint for unpaid wages, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penaltiesPAGA Period, including but not limited to to: (i) all claims under that were alleged, or reasonably could have been alleged, based on the facts contained in the Operative Complaint or ascertained in the course of the Action; and (ii) all PAGA claims, whether representative or individual in nature, that were alleged, or reasonably could have been alleged, based on facts contained in the Operative Complaint, PAGA notice(s), or ascertained in the course of the Action. Such class and PAGA claims include claims for violation of Labor Code sections 510 and 1198 (unpaid overtime), violation of Labor Code sections 226.7 and 512(a) (unpaid meal period premiums), violation of Labor Code section 2698226.7 (unpaid rest period premiums), violation of Labor Code sections 1194 and 1197 (unpaid minimum wages), violation of Labor Code sections 201 and 202 (final wages not timely paid), violation of Labor Code section 226(a) (non-compliant wage statements), violations of Labor Code sections 2800 and 2802 (unreimbursed business expenses), violation of Business & Professions Code section 17200, et seq., Labor Code sections 201, 202, 203, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, all applicable IWC Wage Orders, and Business and Professions Code section 17200 et seq. and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members Except as set forth in Section 5.3 of the Settlement Agreement, Participating Class who Members do not opt out release any other claims, including claims for vested benefits, wrongful termination, violation of the settlementFair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the The Participating Class Members will be bound by the following release: : 6.1 All claims as pled in the ComplaintParticipating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and any further amended pleadings as necessaryassigns, including release Released Parties from (i) all claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698that were alleged, et seq. (“PAGA”) or reasonably could have been alleged, based on the allegations Class Period facts stated in the operative Operative Complaint, as well as any the LWDA Letter, and all wage and hour claims that were asserted or could have been asserted based on the factual allegations contained ascertained in the Complaint, or any amended complaints. This also includes, but is not limited to, any and all claims alleged or that could have been alleged based on the facts course of the Complaint or any amended complaint for unpaid wagesAction including, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to claims for ( a) failure to pay minimum, straight time, overtime, or double time wages, and failure to pay other wages of any kind during employment; (b) failure to authorize and permit rest periods or pay rest period premiums; (c) failure to provide meal periods or pay meal period premiums; (d) failure to provide accurate and itemized wage statements; (e) failure to maintain accurate employment records; (f) failure to pay timely wages; (g) failure to pay final wages due at separation; (h) failure to reimburse or indemnify all necessary business expenses, (i) civil penalties under PAGA based on the alleged Labor Code violations and applicable Wage Orders; (j) claims brought under Business & Professions Code section 269817200, et seq., Labor Code sections 201based on the aforementioned ,including, 202but not limited to all claims for unfair, 203unlawful and harmful conduct to class members, 204, 210, 226, 226.7, 246, 510, 512, 558, 1174, 1174.5 1182.12, 1194, 1194.2 1197, 1197.1, 1198, 2800, 2802, all applicable IWC Wage Ordersthe general public, and Business Defendant’s competitors and Professions Code section 17200 et seq. and any claims of unlawfully gaining an unfair advantage over other businesses, and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damagesinterest, punitive damages, emotional distress damages, reputation damages, any other damagespenalties, attorneys’ fees fees, costs, and costs and interest. For Plaintiff other amounts recoverable based on the aforementioned, to the extent permissible, including, but not limited to, the California Labor Code and the members applicable Wage Orders. 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 Settlement Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).

Participating Class Members’ Release. After the Judgment is final and Defendant 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 and timely excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant Ambitions or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the The Participating Class Members will be bound by 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 releaseclaims: All claims as pled in the ComplaintDocuSign Envelope ID: AC9F757F-60E8-4E69-A505-9939CD2B121B [A]ny and all claims, and any further amended pleadings as necessarydamages, including claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay all Wages Timely Due Upon Separation or causes of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698action alleged in, et seq. (“PAGA”) based on or arising out of, the allegations in the operative ComplaintConsolidated Complaint (as defined below) in the Action that arose during the Class Period and which were alleged, as well as any and all wage and hour claims that were asserted or could have been asserted alleged, by Plaintiffs based on any of the factual allegations contained in the ComplaintConsolidated Complaint in the Action, or any amended complaints. This also includesincluding, but is not limited to, any and all claims alleged under state, federal (i.e., Fair Labor Standards Act (“FLSA”)) or that could have been alleged based on the facts of the Complaint or any amended complaint for unpaid wageslocal law including, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, including but not limited to claims under Labor 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 section 2698§ 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, 246, 510, 512, 558, 558.1, 1174, 1174.5 1182.121174.5, 1194, 1194.2 1194.2, 1197, 1197.1, 1198, 2800, 2800 and 2802, all applicable IWC California Industrial Welfare Commission Wage OrdersOrder 5-2001, California Business and Profession Code sections 17200, et seq., California Code of Civil Procedure section 1021.5, and Business California common law of contract, interest and Professions Code section 17200 et seq. and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, emotional distress damages, reputation damages, attorney’s fees relating in any other damages, attorneys’ fees way to those claims alleged and costs and interest. For Plaintiff and mentioned in the members of Operative Complaint in the Settlement Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”)Action.

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 and timely excluding yourself from the Class Settlement, you xou cannot sue, continue xxntinue to sue, or be part of any other lawsuit against Defendant or related entities for any of the claims alleged in the Action arising during wages based on the Class Period facts or for any and PAGA penalties based on any of the claims alleged in the Action arising during the PAGA PeriodPeriod facts, as alleged in the Action and resolved by this Settlement. Specifically, the The Participating Class Members will be bound by the following release: All claims as pled in the ComplaintParticipating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and any further amended pleadings as necessaryassigns, including claims for (1) Failure to Pay Minimum Wages; (2) Failure to Pay Overtime Wages; (3) Failure to Provide Meal Periods; (4) Failure to Permit Rest Breaks; (5) Failure to Reimburse Business Expenses; (6) Failure to Provide Accurate Itemized Wage Statements; (7) Failure to Pay Wages Timely During Employment; (8) Failure to Pay release Released Parties from all Wages Timely Due Upon Separation of Employment; (9) Violation of Business and Professions Code and (10) Violation of California Labor Code section 2698, et seq. (“PAGA”) based on the allegations in the operative Complaint, as well as any and all wage and hour claims that were asserted or could have been asserted alleged in the Complaints filed in the Actions under any state law, federal law, common law, equity or other theory based on the factual allegations contained facts alleged in the Complaintoperative complaint filed in the Action regarding the provision (or alleged non–provision) of rest breaks, meal breaks, overtime, minimum wage, waiting time penalties, and/or wage statements provided to those class members (or the content or lack of content of any wage statements received), including all claims, rights, demands, liabilities, causes of action, and theories of liability of every nature and description, whether known or unknown, that were alleged against Defendant and/or any of the Released Parties, or any amended complaints. This also includes, but is not limited to, any and all claims alleged or that which could have been alleged based on the facts pled against them in the the Complaints in the Actions. These claims include claims for failure to provide and/or maintain copies of accurate itemized wage statements, failure to provide timely and uninterrupted meal and rest breaks or premium pay in lieu thereof, failure to pay overtime, failure to pay minimum wage (and liquidated damages predicated thereupon), failure to properly calculate the Complaint regular rate of pay, failure to pay minimum wage or any amended complaint overtime as applicable for unpaid wages, economic damages, non-economic damages, any other damages, civil or statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or penalties, hours worked including but not limited to unpaid wages due to inaccurate time rounding or use of an “auto-deduct” feature for meal periods, on-all call compensation, and any and all off-the-clock work, failure to timely pay wages upon separation from employment, unfair competition, and/or for penalties (regardless of the recipient), claims arising under Labor Code section 2698, et seq., California Labor Code sections 201, 202, -203, 204, 210216, 226218.5, 221-223, 224, 225.5, 226,226.2, 226.6, 226.7, 246226.8, 256, 510, 512, 558, 558.1, 1174, 1174.5 1182.12, 1194, 1194.2 1194.2, 1197, 1197.1, 1198, 28001199, 2802, all applicable IWC Wage Orders2751, and 2810.5, damages, interest, costs or attorneys’ fees, and violations of applicable local, state or federal law, whether for economic damages, non- economic damages, liquidated, or punitive damages, restitution, tort, contract, equitable relief, injunctive or declaratory relief, that occurred during the applicable Class Period and based on the facts alleged in the Complaints in the Action, including claims under any common laws, the California Business and & Professions Code section Sections 17200 et seq. (“UCL”), including claims asserted under the UCL predicated on violations of any state and/or federal law alleged in the Complaint and/or Amended Complaints in the Action, including the Cal. Code of Regulations, Title 8, Sections 11000, et seq., any applicable Wage Order, and the California Labor Code. Except as set forth in Section 6.3 of this Agreement, Participating Class Members do not release any and all claims or potential other claims, including claims for lost wages and/or vested benefits, consequential economic damageswrongful termination, other economic damages, punitive damages, emotional distress damages, reputation damages, any other damages, attorneys’ fees and costs and interest. For Plaintiff and the members violation of the Settlement Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class who do not opt out of the settlement, the Settlement Class Release shall include all released claims from November 8, 2017 through August 31, 2023 (“Settlement Class Release Period”).