SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • December 8th, 2020 • California
Contract Type FiledDecember 8th, 2020 JurisdictionThis Settlement Agreement and Release (“Agreement”) is entered into between and among Fred Martin (“Class Representative”), on behalf of himself and the Settlement Class (as hereinafter defined), and Safeway Inc. (“Safeway” and, collectively, the “Parties”). As provided herein, this Agreement fully and finally compromises and settles any and all claims for violation of the Fair and Accurate Credit Transactions Act, 15 U.S.C. §§ 1681 et seq., (“FACTA”), and any and all claims that were or could have been asserted in the lawsuit styled as Martin v Safeway, Inc.. (originally filed as Case No. RG19021180 (Alameda County, Ca.), dismissed without prejudice and refiled as No. (Cir. Ct. Cook County) (the “Litigation”).