Common use of Release by Participating Class Members Clause in Contracts

Release by Participating Class Members. 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 claims for (i) failure to pay wages, including unpaid minimum wages and overtime premium pay; (ii) failure to correctly calculate the regular rate for overtime pay and/or payments for non- complaint meal and/or rest periods; (iii) failure to provide meal and/or rest periods in accordance with applicable law, including payments for meal and/or rest periods; (iv) unreimbursed business expenses; (v) failure to timely pay wages, both during employment and upon termination of employment; (vi) failure to provide accurate itemized wage statements; and (vii) all civil and statutory penalties, including PAGA penalties, arising during the period from August 27, 2016 through seven days prior to final approval (“Class Release 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 Release Period.

Release by Participating Class Members. 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 that reasonably could have been alleged, in the Lawsuit based on the Class Period facts stated in the Operative Complaint and ascertained in the course of the ActionComplaint, including all claims for (i1) failure to pay all minimum wages and liquidated damages; (2) failure to pay all overtime wages, including unpaid minimum wages and overtime premium pay; (ii) but not limited to due to failure to correctly properly calculate the regular rate for overtime pay and/or payments for non- complaint meal and/or rest periodsof pay; (iii3) failure to provide meal and/or rest periods in accordance with applicable law, including payments for meal and/or periods; (4) failure to provide rest periods; (iv) unreimbursed business expenses; (v) failure to timely pay wages, both during employment and upon termination of employment; (vi5) failure to provide accurate accurate, itemized wage statements; (6) waiting time penalties; (7) illegal deductions from wages; (8) failure to reimburse business expenses, and (vii9) all civil and statutory penalties, including PAGA penalties, arising unfair business practices during the period from August 27, 2016 through seven days prior to final approval Class Period (“Class Release PeriodReleased Claims”). Participating Class Members shall release the Released Claims for the entire Class Period, and the judgment on this Settlement will have res judicata effect as to the Released Claims for all Class Members who do not opt-out of this Settlement. 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 Release Period.

Release by Participating Class Members. 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 Complaint, including, e.g., any and ascertained in the course of the Action, including all claims for involving: (i1) any alleged failure to pay wages, wages (including unpaid minimum wages and overtime premium paywage); (ii2) any alleged failure to correctly calculate the regular rate for pay overtime pay and/or payments for non- complaint meal and/or rest periodscompensation; (iii3) any alleged failure to provide compliant meal and/or rest periods periods, or compensation in accordance with applicable law, including payments for meal and/or rest periodslieu thereof; (iv4) unreimbursed business expenses; (v) failure to timely pay wages, both during employment and upon termination of employment; (vi) any alleged failure to provide compliant rest breaks, or compensation in lieu thereof; (5) any alleged failure to provide compliant accurate itemized wage statements; (6) any alleged failure to timely pay wages due upon separation; and (vii7) all civil any alleged unlawful, unfair, or fraudulent business actions or practices under Business and statutory penaltiesProfessions Code §§ 17200, including PAGA penalties, et seq. arising during out of the period from August 27, 2016 through seven days prior to final approval Labor Code and Industrial Welfare Commission (“Class Release PeriodIWC”)) Wage Order violations referenced in the Operative Complaint. 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 Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Release Period.

Release by Participating Class Members. 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 (as well as Class Period facts ascertained in the course of the Action) including, including but not limited to, any and all claims for involving any (ia) failure to pay minimum wages, including unpaid minimum wages and overtime premium pay; (iib) failure to correctly calculate the regular rate for pay overtime pay and/or payments for non- complaint meal and/or rest periodswages; (iiic) failure to provide meal and/or rest periods in accordance with applicable law, or timely meal periods (including payments for failure to pay meal and/or rest periodsperiod premiums); (iv) unreimbursed business expenses; (v) failure to timely pay wages, both during employment and upon termination of employment; (vid) failure to provide accurate itemized wage statements; (e) failure to pay wages due upon termination; (f) failure to pay reimbursable expenses; (g) violation of Business & Professions Code § 17200, et. seq.; (h) failure to pay all wages due; and (viii) all civil and statutory penaltiesviolation of Labor Code § 2698, including PAGA penaltieset. seq. Except as set forth in Section 6.3 of this Agreement, arising during the period from August 27, 2016 through seven days prior to final approval (“Class Release 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 Release Period.