Common Contracts

JOINT STIPULATION OF CLASS ACTION AND PAGA SETTLEMENT

Joint Stipulation of Class Action and Paga Settlement • January 13th, 2023 • California

• Contract Type
  Joint Stipulation of Class Action and Paga Settlement
• Filed
  January 13th, 2023
• Jurisdiction
  California

Subject to final approval by the Court, it is stipulated, by and between Plaintiff Andrea Marquez (“Plaintiff”), on behalf of herself, other similarly situated putative class members, and other aggrieved employees, and Defendants Nihon Kohden America, Inc. and Vaco LLC (“Defendants”) that the Action is hereby compromised and settled pursuant to the terms and conditions set forth in this Joint Stipulation of Class Action and PAGA Settlement (“Settlement Agreement,” “Settlement,” or “Agreement”) and that the Court shall make and enter judgment subject to the definitions, recitals, and terms set forth herein, which by this reference become an integral part of the Agreement. Plaintiff and Defendants are collectively referred to in this Agreement as the “Parties.”