CLASS ACTION SETTLEMENT AGREEMENTClass Action Settlement Agreement • March 22nd, 2019 • California
Contract Type FiledMarch 22nd, 2019 JurisdictionThis Class Action Settlement Agreement (hereinafter the “Settlement Agreement” or “Agreement”) is made by the Named Plaintiffs, as defined in this Agreement, on behalf of themselves and all others similarly situated (including the Settlement Class as defined below) (collectively “Plaintiffs”), and Defendant Maplebear, Inc. dba Instacart (“Instacart” or “Defendant”), in the action captioned: Groves, et al. v. Maplebear, Inc. d/b/a Instacart, currently pending in the Superior Court for the State of California for the County of Los Angeles, Case No. BC695401, as amended pursuant to this Agreement (herein “Groves” and also referred to hereinafter as “the Litigation”).