JOINT STIPULATION OF CLASS ACTION AND REPRESENTATIVE ACTION SETTLEMENT AND RELEASESettlement Agreement • January 13th, 2023 • California
Contract Type FiledJanuary 13th, 2023 JurisdictionThis Joint Stipulation of Class Action and Representative Action Settlement and Release (hereinafter “Settlement Agreement”) is made and entered into by and between the following parties: Plaintiff Alison Andrade (“Plaintiff”), individually and on behalf of other members of the general public similarly situated and as a proxy of the State of California and the California Labor and Workforce Development Agency (“LWDA”) on behalf of all other allegedly aggrieved employees, and Defendant Urban Outfitters, Inc. (“Urban”) (collectively, the “Parties”), and their respective counsel of record. This Settlement Agreement is subject to the terms and conditions set forth below and to the approval of the Court. This Settlement Agreement supersedes any and all prior memoranda of understanding and accurately sets forth the Parties’ class action and representative action settlement to resolve all claims as detailed below.