STIPULATED SETTLEMENT AGREEMENT AND RELEASE OF CLAIMSSettlement Agreement • November 12th, 2024
Contract Type FiledNovember 12th, 2024The Parties to this Stipulated Settlement Agreement and Release of Claims (the “Agreement” or “Settlement Agreement”) are Plaintiff Andrea Otanez Verdugo (“Plaintiff”), for herself and acting on behalf of the Settlement Class (as defined below), the State of California, and the Private Attorneys General Act (“PAGA”) Representative Group (as defined below), on the one hand, and defendant Capstone Logistics, LLC (“Defendant” or “Capstone”) on the other, with respect to the civil action pending between Plaintiff and Defendant (collectively at times the “Parties”) entitled Andrea Otanez Verdugo v. Capstone Logistics, LLC, in arbitration before the Honorable Hunter H. Hughes (the “Arbitration” or “Action”)1.