Common Contracts

SETTLEMENT AGREEMENT

Settlement Agreement • December 12th, 2018 • California

• Contract Type
  Settlement Agreement
• Filed
  December 12th, 2018
• Jurisdiction
  California

This Settlement Agreement (“Agreement,” the terms of which are sometimes referred to as the “Settlement”) is entered into by and between Cathie Cruz (“Cruz”), Shannon Dale Price (“Price”), Cheryl Edgemon (“Edgemon”), Robert Davenport (“Davenport”), Patrick Bergeron (“Bergeron”), and Mary Schnurer (“Schnurer”), on the one hand, on behalf of themselves and all other individuals who are members of the Class as defined in Section III below, and Synapse Group, Inc. and SynapseConnect, Inc. (together referred to as “Synapse” or “defendants”), on the other hand. Each of the foregoing is a “Party” (collectively, the “Parties”).