Common Contracts

STIPULATION AND AGREEMENT OF SETTLEMENT

Settlement Agreement • October 10th, 2011

• Contract Type
  Settlement Agreement
• Filed
  October 10th, 2011

This Stipulation and Agreement of Settlement dated below (the “Stipulation”), is made and entered into by and among: (i) Moraima Ramon (“Lead Plaintiff”), on behalf of herself and the Class (as defined herein), by and through her respective counsel of record in the Litigation (“Lead Counsel”); and (ii) City of Hallandale Beach (“City”), American Traffic Solutions LLC, and ATS American Traffic Solutions, Inc. (defined, together with certain other entities, at ¶ 1.5 of this Stipulation “ATS”), by and through their counsel of record in the Litigation (as defined herein). The City and ATS are collectively referred to as the “Settling Defendants.” Lead Plaintiff and the Settling Defendants are collectively referred to as the “Parties” or the “Settling Parties.” The Stipulation is intended by the Settling Parties to fully, finally and forever resolve, discharge and settle the Litigation and all Released Claims against all Released Persons (as defined herein), upon and subject to the terms an