Release by Plaintiff. From and after the execution of this Agreement, and with the exception of obligations under this Agreement, Plaintiff hereby releases and forever discharges, on his behalf and on behalf of his heirs, agents, and legal representatives, Defendants and each of their heirs, agents, legal representatives, and successors to office from any and all known or unknown claims, demands, and causes of action of any sort and all damages, in equity or contract, that Plaintiff has arising prior to the date of this Agreement and relating to or assertable in connection with the Diversity Clerkship Program (altogether, the “Released Matters”). The Parties understand that this Release is personal to the Plaintiff and that Plaintiff has no ability to release or waive any claims relating to the Diversity Clerkship Program by other members of the State Bar, law students (current or future), or any other third party.
Release by Plaintiff. Plaintiff on behalf of himself and his heirs, executors, estates, predecessors, successors, assigns, agents and representatives, hereby release any and all claims, liens, demands, causes of action, obligations, damages, and liabilities, known or unknown, suspected or unsuspected, fixed or contingent, which he has or may have against any of the Released Parties that arose before the date this Agreement is executed. The release is intended to be a general one covering all existing claims or demands of any nature whatsoever. Plaintiff expressly understand and acknowledge that it is possible that unknown losses or claims exist or that present losses may have been underestimated in amount or severity. The Parties to this Agreement explicitly took that possibility into account in entering into this Agreement. A portion of the consideration has been bargained for between the Parties to this Agreement with the knowledge of the possibility of such unknown losses or claims and was given in exchange for a full accord, satisfaction, and discharge of all such losses or claims. Consequently, Plaintiff, for himself, expressly waive all rights under California Civil Code § 1542, which provides: This release will become effective on the date the Defendant has rendered full payment in this matter to the class action administrator.
Release by Plaintiff. Except as to such rights as are created or preserved by this Agreement, in consideration for the payments described in Section 4.3, above, Plaintiff (hereinafter called the “Releasor”), does hereby forever release and discharge Defendants, and any of their respective subsidiaries, subdivisions, parent corporations, officers, directors, agents, insurers, reinsurers, attorneys, servants or employees, and all others (hereinafter collectively called the “Releasees”) from any and all actions, causes of action, obligations, costs, damages, losses, claims, liabilities and demands (including claims arising out of contract), arising out of or in any way connected with or resulting from the accident which allegedly occurred on December 30, 2015 near 000 Xxxxxxxxx Xxxxxx in Redwood City, California, and all of those matters set forth in the Subject Action, as a result of which personal injury and other loss and damage were alleged to have been sustained by Plaintiff.
Release by Plaintiff. In light of Plaintiff Class Representative Incentive Award (discussed below), Plaintiff has agreed to release, in addition to the Class Released Claims and PAGA Released Claims described above, all claims, whether known or unknown, under federal or state law, against the Released Parties, to the extent permitted by law, through the date this Settlement is signed by Plaintiff s benefits afforded by Section 1542 of the California Civil Code, which provides: Specifically excluded from Plaintiff s otherwise Released Claims are any and all claims that cannot be released as a matter of law, including, but not limited to, claim(s) California or California Unemployment benefits (EDD). No Work Compensation claims/actions are being settled, resolved or released under this Settlement Agreement.
Release by Plaintiff. Except or the rights and obligations specifically set forth in this Agreement, Plaintiff, for itself and its heirs, successors, predecessors, assigns, agents, attorneys, insurers, representatives, employees, officers, members and managers and any other person or entity acting or purporting to act by, through, under or in concert with them (collectively with Plaintiff, the “Plaintiff Releasors”) hereby release and discharge Defendant, the heirs of the Defendant, and, in their capacities in acting on behalf of Defendant, each of their successors, predecessors, assigns, agents, attorneys, insurers, representatives, employees, officers, directors and any other person or entity acting or purporting to act by, through, under or in concert with him, her or it, from any and all debts, damages, liabilities, demands, obligations, costs, expenses, disputes, manner of claims, rights, actions and causes of action, whether known or unknown, vested or contingent, pursuant to federal or state statute, common law or otherwise, which either Plaintiff Releasor now owns or holds or has at any time heretofore owned or held or has asserted, or hereafter can, shall or may have or assert, for, upon or by reason of any matter, cause or thing whatsoever from the beginning of the world to the Effective Date.
Release by Plaintiff. As of the Effective Date, Plaintiff absolutely and unconditionally releases and forever discharges the Released Parties from any and all causes of action, suits, debts, dues, damages, including compensatory and punitive damages, medical payment benefits, sums of money, accounts, reckonings, bonds, bills, covenants, contracts, contro- versies, agreements, promises, claims and demands of whatsoever kind or nature, in law or in equity, whether asserted or unasserted, actual or contingent, anticipated or unanticipated, known or unknown, which Plaintiff ever had or now has against the Released Parties from the beginning of time through the entry of the Final Approval Order.
Release by Plaintiff. For the purpose of implementing a full and complete release and discharge, the Plaintiff expressly acknowledges that the release given in the Settlement Agreement is intended to include, without limitation, that with respect to the Plaintiff’s Released Claims, all claims that she alleged or could have alleged in the PAGA and Class Action Complaints against Defendant or the Released Parties, that she did not know or suspect at the time of execution hereof, regardless of whether the knowledge of such claims, or the facts upon which they might be based, would materially have affected the settlement of the Settled Lawsuits, and that the consideration given under this Settlement Agreement is also for the release of those claims and contemplates the extinguishment of any such claims against the Released Parties. Plaintiff shall hereby knowingly, voluntarily and completely release the Released Parties as defined in this Settlement Agreement from/for all the Plaintiff’s Released Claims. Other than the Class Complaint, the PAGA Complaint, and the Individual Complaint, Plaintiff represents she has no other lawsuit, administrative complaint, or charge against the Released Parties in any local, state or federal court or administrative agency. Plaintiff further acknowledges that all claims raised in the Class Complaint and the PAGA Complaint shall be fully and finally extinguished by virtue of this Settlement Agreement and the Court’s Final Approval Order. Plaintiff further represents that she will not bring any action in the future in which she seeks to recover any damages from Defendant or the Released Parties relating to or arising from Plaintiff’s employment with Defendant, other than an action to enforce their rights under this Settlement Agreement. Plaintiff is bound by the Settlement Agreement regardless of whether she cashes her settlement check.
Release by Plaintiff. In consideration of the mutual promises between the Parties, Plaintiff, her family, successors, and assigns completely release and forever discharge the City, its past, present and future officers, directors, stockholders, attorneys, agents, servants, representatives, employers, employees, subsidiaries, affiliates, partners, predecessors, successors and assigns of and from any and all past, present or future claims, demands, obligations, actions, causes of action, damages, exemplary damages, costs, attorney’s fees, losses of services, expenses and compensation of any nature whatsoever, whether based on tort, contract or other theory of recovery, which Plaintiff now has, or which may hereafter accrue or otherwise be acquired, arising out of or in any way relating to the INCIDENT. This Release and Discharge shall be a fully binding and complete settlement between the Parties, their affiliates, assigns, predecessors and successors.
Release by Plaintiff. Plaintiff, on behalf of itself and its successors, predecessors, parents, subsidiaries, affiliated companies, administrators, officers, directors, employees, shareholders, agents, representatives, descendents, dependents, heirs, spouses, partners, executors, assigns and successors, hereby fully, completely and finally waives, releases and forever discharges and covenants not to xxx the Defendant and its respective successors, predecessors, parents, subsidiaries, affiliated companies, administrators, officers, directors, employees, shareholders, attorneys, insurers, agents, representatives, descendents, dependents, heirs, spouses, partners, executors, assigns and successors, and each of them (collectively, the "Defendant Released Parties") from any and all claims, demands, suits, liabilities, debts and obligations of any kind or nature, known or unknown, suspected or unsuspected, and whether concealed or hidden, which it ever had, now has or may have in the future against any of the Defendant Released Parties: (1) that were asserted or could have been asserted in the Civil Action; or (2) arising out of or relating in any way to the facts and circumstances set forth in the Civil Action (collectively the "Released Claims"); provided, however, that this release does not apply to any obligations expressly created by this Agreement, or documents provided pursuant hereto.
Release by Plaintiff. As consideration for this Agreement, as of the Effective Date, Plaintiff releases and forever discharges the Released Parties from any and all causes of action, suits, debts, dues, damages, including compensatory and punitive damages, medical payment benefits, sums of money, accounts, reckonings, bonds, bills, covenants, contracts, controversies, agreements, promises, claims and demands of whatsoever kind or nature, in law or in equity, whether asserted or unasserted, actual or contingent, anticipated or unanticipated, known or unknown, which Plaintiff ever had or now has against Defendant from the beginning of time through the Effective Date. This release does not limit or foreclose any defenses Plaintiff may have regarding the underlying debt Defendant sought to collect from him.
