A MENDED SETTLEMENT AGREEMENTSettlement Agreement • October 16th, 2019 • California
Contract Type FiledOctober 16th, 2019 JurisdictionThis Settlement Agreement, dated as of September 20, 2019, is made and entered into by and among the following Settling Parties (as defined below): (i) Kushroo Khavarian (“Plaintiff”), individually and on behalf of the Settlement Class (as defined below), by and through his counsel at The Sultzer Law Group, Shoop, A.P.C., and Access Lawyers Group (“Proposed Class Counsel”); and (ii) Jerome’s Furniture Warehouse (“Jerome’s”), by and through its counsel of record, Dentons US LLP (“Jerome’s Counsel”). The Settlement Agreement is subject to Court approval and is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined below), upon and subject to the terms and conditions hereof.