JOINT STIPULATION OF CLASS ACTION AND PAGA SETTLEMENTJoint Stipulation of Class Action and Paga Settlement • November 14th, 2022 • California
Contract Type FiledNovember 14th, 2022 JurisdictionSubject to final approval by the Court, it is stipulated, by and between Plaintiffs Jasfer Nepomuceno and Danielle Winkle (“Plaintiffs”), individually and on behalf of the Participating Class Members, and Defendant Portfolio Recovery Associates, LLC (“Defendant”) that the Action is hereby compromised and settled pursuant to the terms and conditions set forth in this Joint Stipulation of Class Action and PAGA Settlement and Release of Claims (“Settlement Agreement”) and that the Court shall make and enter judgment subject to the definitions, recitals, and terms set forth herein, which by this reference become an integral part of the Settlement Agreement. Plaintiffs and Defendant collectively are referred to in this Settlement Agreement as the “Parties.”