STIPULATION OF SETTLEMENTSettlement Agreement • July 22nd, 2022
Contract Type FiledJuly 22nd, 2022This Stipulation of Settlement (“Settlement Agreement”) is reached by and between Plaintiff Roberto Navarro (“Plaintiff” or “Class Representative”), individually and on behalf of all members of the Settlement Class (defined below), on one hand, and Prime Converting Corporation (“Defendant”), on the other hand. Plaintiff and Defendant are referred to herein collectively as the “Parties.” Plaintiff and the Settlement Class are represented by Paul K. Haines, Sean M. Blakely and Alexandra R. McIntosh of Haines Law Group, APC (collectively, “Class Counsel”). Defendant is represented by Robert Prata of Prata & Daley LLP.