JOINT STIPULATION OF CLASS ACTION AND PAGA SETTLEMENTCalifornia • January 13th, 2023
Jurisdiction FiledJanuary 13th, 2023Subject 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.”