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Contract Type FiledAugust 25th, 2020 JurisdictionPlaintiffs and Class Representatives Artem V. Gelis, Bhawar Patel, Robert McDonald, James V. Olson, Gregory Heyman, Susan Heyman, Debra P. Ward, Darrian Stovall, Alex Martinez, Amanda Gorey, Chris Williams, Ashok Patel, Kenneth Gagnon, Michael Cerny, Maria Meza, Andre Malske, Nicole Guy, David Richardson, Stacey Turner, and Eric T. Zinn (“Plaintiffs” or “Class Representatives”), by and through their counsel, and Defendant BMW of North America, LLC (“BMW NA” or “Defendant”), by and through its counsel, hereby enter into this Settlement Agreement providing, subject to the approval of the Court, for the settlement of the claims herein described against BMW NA (the “Settlement”).