RELEASES OF CLAIMS. Effective on the date when Defendants fully fund the entire Gross Settlement Amount and fund all employer payroll taxes owed on the Wage Portion of the Individual Class Payments, Plaintiff, Class Members, and Class Counsel will release claims against all Released Parties as follows: 1. Plaintiff’s Release. Plaintiff and his former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally release and discharge Released Parties from all claims, transactions, or occurrences of any nature arising from Plaintiff’s employment with Defendant whether known or unknown, which exist or may exist as of the Parties’ execution of this Agreement, including, but not limited to: (a) all claims that were, or reasonably could have been, alleged based on the facts contained in the Operative Complaint; and (b) all PAGA claims that were, or reasonably could have been, alleged based on facts contained in the PAGA Notice (“Plaintiff’s Release”). Plaintiff’s Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ compensation benefits that arose at any time, or based on occurrences outside the Class Period. Plaintiff acknowledges he may discover facts or law different from, or in addition to, the facts or law Plaintiff now knows or believes to be true. But Plaintiff agrees that Plaintiff’s Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s discovery of them.
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RELEASES OF CLAIMS. Effective on the date when Defendants Defendant fully fund funds the entire Gross Settlement Amount and fund funds all employer payroll taxes owed on the Wage Portion of the Individual Class Payments, Plaintiff, Class Members, and Class Counsel will release claims against all Released Parties as follows:
1. 6.1 Plaintiff’s Release. Plaintiff and his or her respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally generally, release and discharge Released Parties from all claims, transactions, or occurrences of any nature arising from Plaintiff’s employment with Defendant whether known or unknown, which exist or may exist as of [that occurred during the Parties’ execution of this AgreementCovered Period, including, but not limited to: (a) all claims that were, or reasonably could have been, alleged alleged, based on the facts contained contained, in the Operative Complaint; Complaint and (b) all PAGA claims that were, or reasonably could have been, alleged based on facts contained in the Operative Complaint, Plaintiff’s PAGA Notice Notice, [or ascertained during the Action and released under 6.2, below]. (“Plaintiff’s Release.”). ) Plaintiff’s Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ compensation benefits that arose at any time, or based on occurrences outside the Class Covered Period. Plaintiff acknowledges he that Plaintiff may discover facts or law different from, or in addition to, the facts or law that Plaintiff now knows or believes to be true. But Plaintiff agrees true but agrees, nonetheless, that Plaintiff’s Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s discovery of them.
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RELEASES OF CLAIMS. Effective on the date when Defendants fully fund the entire Gross Settlement Amount and fund all employer payroll taxes owed on the Wage Portion of the Individual Class Payments, Plaintiff, Class Members, and Class Counsel will release claims against all Released Parties as follows:
1. Plaintiff’s 5.1 Plaintiffs Release. Plaintiff and his or her respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, and assigns generally generally, release and discharge Released Parties from all claims, transactions, or occurrences of any nature arising from Plaintiff’s employment with Defendant whether known or unknown, which exist or may exist as of the Parties’ execution of this Agreementoccurrences, including, but not limited to: (a) all claims that were, or reasonably could have been, alleged alleged, based on the facts contained and allegations contained, in the Operative Complaint; Complaint and (b) all PAGA claims that were, or reasonably could have been, alleged based on facts and allegations contained in the Operative Complaint, Plaintiffs PAGA Notice Notice, or ascertained during the Action and released under 5.3 and 5.5 below (“Plaintiff’s Release”). Plaintiff’s Plaintiffs Release.) Plaintiffs Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ workers compensation benefits that arose at any time, or based on occurrences outside the Class Period. Plaintiff acknowledges he that Plaintiff may discover facts or law different from, or in addition to, the facts or law that Plaintiff now knows or believes to be true. But Plaintiff agrees true but agrees, nonetheless, that Plaintiff’s Plaintiffs Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s Plaintiffs discovery of them.
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Samples: Settlement Agreement
RELEASES OF CLAIMS. Effective on the date when Defendants Defendant fully fund funds the entire Gross Settlement Amount and fund funds all employer payroll taxes owed on the Wage Portion of the Individual Class Payments, Plaintiff, Class Members, and Class Counsel will release claims against all Released Parties as follows:
1. Plaintiff’s 6.1 Plaintiffs Release. Plaintiff and his respective former and present spouses, representatives, agents, attorneys, heirs, administrators, successors, successors and assigns generally generally, release and discharge Released Parties from all claims, transactions, transactions or occurrences of any nature arising from Plaintiff’s employment with Defendant whether known or unknown, which exist or may exist as of the Parties’ execution of this Agreementclaims for relief alleged in the Operative Complaint and that occurred during the Class Period, including, but not limited to: (a) all claims that were, or reasonably could have been, alleged alleged, based on the facts contained contained, in the Operative Complaint; Complaint and (b) all PAGA claims that were, or reasonably could have been, alleged based on facts contained in the Operative Complaint, Plaintiffs PAGA Notice (“Plaintiff’s Release”Plaintiffs Release). Plaintiff’s Plaintiffs Release does not extend to any claims or actions to enforce this Agreement, or to any claims for vested benefits, unemployment benefits, disability benefits, social security benefits, workers’ workers compensation benefits that arose at any time, or based on occurrences outside the Class Period. Plaintiff acknowledges he that Plaintiff may discover facts or law different from, or in addition to, the facts or law that Plaintiff now knows or believes to be true. But Plaintiff agrees true but agrees, nonetheless, that Plaintiff’s Plaintiffs Release shall be and remain effective in all respects, notwithstanding such different or additional facts or Plaintiff’s Plaintiffs discovery of them.
6.1.1 Plaintiffs Waiver of Rights Under Civil Code Section 1542. For purposes of Plaintiffs Release, Plaintiff expressly waives and relinquishes the provisions, rights, and benefits, if any, of section 1542 of the Civil Code, which reads:
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