CLASS ACTION SETTLEMENT AGREEMENTClass Action Settlement Agreement • February 15th, 2022 • Illinois
Contract Type FiledFebruary 15th, 2022 JurisdictionThis Class Action Settlement Agreement (“Agreement”) is entered into by and amongst Plaintiff Lynn Watson, on behalf of herself and the Settlement Class Members (“Plaintiff”), on the one hand, and Defendant E.T. Browne Drug Co., Inc., (“E.T. Browne” or “Defendant”) on the other hand. E.T. Browne and Plaintiff are sometimes hereinafter are referred to individually as a “Party” and collectively as the “Parties.” Capitalized terms used herein are defined in Section II of this Settlement or indicated in parentheses elsewhere in this Agreement. Subject to the Court’s approval, the Parties hereby stipulate and agree that, in consideration for the promises and covenants set forth in the Agreement and upon the entry by the Court of a Final Approval Order and the occurrence of the Effective Date, the Action shall be settled and compromised, and Plaintiff and Settlement Class Members will release claims in favor of the Released Parties (as hereinafter defined), upon the terms and conditions cont