Common Contracts

JOINT STIPULATION OF SETTLEMENT AGREEMENT AND

Settlement Agreement • June 26th, 2020 • California

• Contract Type
  Settlement Agreement
• Filed
  June 26th, 2020
• Jurisdiction
  California

This Joint Stipulation of Settlement Agreement and Release is made and entered between and among Defendant Swift Beef Company and Defendant JBS USA Food Company Holdings (collectively, “Defendant”) and Plaintiff Silvia Valdivia De Cabrera and Plaintiff Eddie Duron (“Plaintiffs”), on their own behalf and on behalf of a putative class and each of its Class Members (as defined herein) in Silvia Valdivia De Cabrera v. Swift Beef Company, Case No. 5:18-cv-02551-PSG-E, and Eddie Duron v. JBS USA Food Company Holdings, Case No. 5:19-cv-00702-PSG-E (together, “the Litigation”), with the assistance of counsel. Plaintiffs and Defendant are referred to in this Agreement collectively as the “Parties.” Subject to the approval of the Court, the Parties agree that the Litigation and the Released Claims and PAGA Released Claims (as defined herein) shall be fully and finally compromised, settled and released, and dismissed with prejudice and final judgment be entered upon the terms and conditions as se