SETTLEMENT AGREEMENTSettlement Agreement • February 4th, 2022
Contract Type FiledFebruary 4th, 2022This Settlement Agreement (the “Settlement Agreement” or the “Agreement”) is made and entered into as of this 28th day of January, 2022, by and between Plaintiffs Michael Zhao, Dean Marriott and Mary Kay Peck (“Plaintiffs”), individually and as representatives of the Settlement Class defined below, and Volkswagen Group of America, Inc. (“VWGoA” or “Defendant”) (collectively, the “Parties”).