SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • October 4th, 2024 • Illinois
Contract Type FiledOctober 4th, 2024 JurisdictionThis Settlement Agreement and Release (“Settlement Agreement” or “Agreement”) is entered into by and between Plaintiffs Michael Shields, Daniel Berndt, Julio Perez, Augustyn Wiacek, Deidra Clay, Eric Flores and Rock Meyer (collectively, “Plaintiffs”), individually and on behalf of all Settlement Class Members (as defined in Paragraph 44), Defendant Bryan Cave Leighton Paisner LLP (“BCLP”) and Defendant Mondelēz Global LLC (“Mondelēz”) (together, “Defendants,” and with Plaintiffs, the “Parties”), in the consolidated action styled In re: Mondelēz Data Breach Litigation, Master File No. 1:23-cv-03999, pending in the United States District Court for the Northern District of Illinois (the “Action”).