Settlement Class Member Release. Upon the Effective Date, Plaintiffs and each Settlement Class Member, including any present, former, and future spouses, as well as the present, former, and future heirs, executors, estates, administrators, representatives, agents, attorneys, partners, successors, predecessors, and assigns of each of them, shall release, waive, and forever discharge Target and each of its present, former, and future parents, predecessors, successors, subsidiaries, assigns, assignees, affiliates, conservators, divisions, departments, subdivisions, owners, partners, principals, trustees, creditors, shareholders, joint venturers, co- venturers, officers, and directors (whether acting in such capacity or individually), attorneys, vendors, insurers, accountants, nominees, agents (alleged, apparent, or actual), representatives, employees, managers, administrators, and each person or entity acting or purporting to act for them or on their behalf (collectively, “Target Releasees”) from any and all claims that: (a) arise from or relate to the conduct alleged in the Actions;
Settlement Class Member Release. Upon the Effective Date, in exchange for the consideration set 15 forth herein, Plaintiff and all other Settlement Class Members will release the Released Parties from those 16 claims and causes of action alleged in the Complaint as well as any and all claims and causes of action that could reasonably have been alleged based on the facts set forth in the Complaint and arising during the Class Period.
Settlement Class Member Release. Upon final approval of this Settlement Agreement by the Court, each and every Settlement Class member who does not timely opt-out in accordance with the procedures set forth in Paragraph 17 -- whether or not they are a Participating Class Member -- releases Defendant, Fidelity Life Association, and their predecessors, successors, parents, subsidiaries, insurers, and related or affiliated entities (including, without limitation, their present, former, and future officers, directors, stockholders, managers, agents, employees, attorneys, and representatives) (the “Released Parties”) from any and all claims for violations of RCW 49.62, known or unknown, that were or could have been asserted, and/or accrued during or arise out of or relate to their employment with Defendant and or the Released Parties, relating back to the full extent of the federal and state statutes of limitations and continuing through the date of final approval, including, without limitation, all claims for noncompetition covenant violations and related claims for penalties, fines, damages, interest, liquidated damages, exemplary damages, attorneys’ fees, costs, and expenses. Defendant represents that, as of the March 1, 2023, mediation, Fidelity Life Association had no Washington employees.
Settlement Class Member Release. Upon final approval of this Settlement Agreement by the Court, each Settlement Class member who does not timely opt-out in accordance with the procedures set forth in Paragraph 14 will release any and all claims for violations of RCW
Settlement Class Member Release. Settlement Class members who do not request exclusion from the settlement after distribution of the Class Notice and the opportunity to opt-out will release (i) Defendants and their parents, subsidiaries, affiliates, related companies/corporations and/or partnerships (defined as a company/corporation and/or partnership that are, directly or indirectly, under common control with Defendants or any of their parents and/or affiliates), joint ventures, joint employers, alter-egos, divisions, insurers, insurance policies and benefit plans, (ii) each of the past, present, and future officers, directors, agents, employees, equity holders (shareholders, holders of membership interests, etc.), representatives, administrators, fiduciaries and attorneys of the entities and plans described in this sentence, and
Settlement Class Member Release. Upon final approval of this Settlement Agreement by the Court, each Settlement Class Member who does not submit a timely request for exclusion in accordance with the procedures set forth in Paragraph 14(a) will release, waive, and forever discharge: (i) Defendants and each of their respective parents, subsidiaries, affiliates, related companies/corporations and/or partnerships (defined as a company/corporation and/or partnership that are, directly or indirectly, under common control with Defendants or any of their parents and/or affiliates), investors, owners, joint ventures, joint employers, alter-egos, divisions, insurers, insurance policies, and benefit plans, or any other entity with an interest in or obligation regarding Defendants’ liabilities, (ii) each of the past, present, and future officers, directors, agents, employees, equity holders (shareholders, holders of membership interests, etc.), representatives, administrators, fiduciaries and attorneys of the entities and plans described in this sentence, and
Settlement Class Member Release. Upon final approval of this Settlement Agreement by the Court, each Settlement Class Member who does not submit a timely request exclusion in accordance with the procedures set forth in Paragraph 14 will release (i) Defendant and its parents, subsidiaries, affiliates, related companies/corporations and/or partnerships, joint ventures, joint employers, alter-egos, divisions, insurers, insurance policies and benefit plans (ii) each of the past, present, and future officers, directors, agents, employees, equity holders (shareholders, holders of membership interests, etc.), representatives, administrators, fiduciaries and attorneys of the entities and plans described in this sentence, and (iii) the predecessors, successors, transferees, and assigns of each of the persons and entities described in this sentence (the “Released Parties”) from any and all claims during the Settlement Class Period that were or could have been asserted against Defendant by Plaintiff and members of the Settlement Class based on the facts and claims asserted in Plaintiff’s Complaint, including any claims under any state, federal, or local law, to the fullest extent permitted by law (the “Released Class Claims”).
Settlement Class Member Release. Upon the Effective Date, and in consideration of the settlement relief and other consideration described herein, the Releasing Parties, and each of them, shall be deemed to have released, and by operation of the Final Approval Order shall have, fully, finally, and forever released, acquitted, relinquished and completely discharged the Released Parties from any and all Released Claims
