SETTLEMENT AGREEMENTSettlement Agreement • October 18th, 2021 • Virginia
Contract Type FiledOctober 18th, 2021 JurisdictionThis Settlement Agreement (“Agreement”) is made and entered into by Plaintiff Dawn Angione on behalf herself and others similarly situated to her who were employed as Therapeutic Day Treatment Counselors (“TDT Counselors”) (collectively, “Plaintiffs”) by Defendants National Counseling Group, Inc. and Francis A. Viera, Jr. (together, “NCG”), between June 1, 2017 and November 28, 2020 (“Statutory Time Period”) and is conditioned upon final judicial approval. NCG, Angione and Opt-In Plaintiffs (collectively the “Settling Parties”) do hereby agree to do all things and procedures necessary and appropriate to obtain approval of this Agreement in consideration for: (a) payment by NCG of the consideration expressed herein subject to the terms, conditions and limitations of this Agreement; (b) the release and dismissal with prejudice of all claims of failure to pay overtime compensation for work performed during the statutory time period by the Plaintiffs who become Settlement Collective Member