SETTLEMENT AGREEMENT AND RELEASE OF CLAIMSSettlement Agreement • April 19th, 2019 • California
Contract Type FiledApril 19th, 2019 JurisdictionThis Settlement Agreement and Release of Claims (“Agreement”) is entered into by plaintiffs, RONNEL CARTER, the estate of JUAN ESTRADA, the estate of JERRY GREEN, BURL MALMGREN, BILL McDONALD, and JOEL MORALES individually and on behalf of the Settlement Class, as defined below, and defendant, XPO LAST MILE, INC. This Agreement is subject to approval of the Court pursuant to Rule 23(e) of the Federal Rules of Civil Procedure, and is made for the sole purpose of attempting to consummate settlement of this Action on a classwide basis subject to the following terms and conditions. As detailed below, in the event the Court does not enter an order granting final approval of the Settlement for any reason, this Agreement shall be void and shall be of no force or effect.