SETTLEMENT AGREEMENT AND RELEASE OF CLAIMS AND RIGHTSSettlement Agreement • October 21st, 2020 • California
Contract Type FiledOctober 21st, 2020 JurisdictionParties. This Settlement Agreement and Release of Claims and Rights (the “Agreement” or the “Settlement”), is entered into as of the 27th day of July, 2020, by and between: (a) plaintiffs Richard Winters (“Winters”) and Jake Gruber (“Gruber”) (collectively “Plaintiffs”), on behalf of themselves and as class representatives acting on behalf of the Class Members defined below; and (b) Forbidden Fruit Ciderhouse, LLC, doing business as 2 Towns Ciderhouse, erroneously sued and named as defendant in the Winters Action (defined below) as “Two Towns Ciderhouse Inc.” (“2 Towns” or “Defendant”). Plaintiffs and 2 Towns are each referred to herein as a “Party” and collectively as the “Parties.” This Agreement is intended by the Parties to finally and fully compromise, settle and forever resolve all claims specified below, subject to the terms and conditions herein.