SETTLEMENT AGREEMENTSettlement Agreement • August 21st, 2018 • District of Columbia
Contract Type FiledAugust 21st, 2018 JurisdictionThis Settlement Agreement (“Agreement”) is made and entered into by and among Class and/or Collective Action Representative Plaintiffs Shayn Stephens, Vanessa Calvillo, Sylvia Krohn, Shannon Storey, Anita Clark, Jeanine Willig, and Desmond Pitt ("Class Representatives") on behalf of themselves and Fair Labor Standards Act ("FLSA") Opt-In Plaintiffs as defined in Paragraph 1.1, and all Rule 23 State Law Class Members as defined in Paragraph 1.2 (collectively “Plaintiffs”), and Defendants Farmers Restaurant Group, LLC, Dan Simons, and Michael Vucurevich (collectively “Defendants” or “FRG”), and is based on the following: