SETTLEMENT AGREEMENTSettlement Agreement • November 18th, 2020
Contract Type FiledNovember 18th, 2020This Settlement Agreement (“Agreement”) is made and entered into on January 23 , 2020 (“Execution Date”) by and between PMGOA, Inc. and Defendants Gennex Media, LLC, Brandeco, L.L.C., and Akil Kurji (collectively, “Gennex Defendants”), on the one hand, and Class Representatives Kimberly Kjessler, Klaire Rueckert, Laura Braley, Timothy Hayden, and Summer Lang, for themselves individually and on behalf of all Class Members (collectively “Plaintiffs” or the “Class,” and together with Gennex Defendants, “Parties”) as defined below, on the other. (All Defendants in this litigation, including the Gennex Defendants and the other, non-settling Defendants, are referenced collectively as “Defendants” in this Agreement.) This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims, upon and subject to the terms and conditions herein, subject to Court approval.