SETTLEMENT AGREEMENTSettlement Agreement • April 10th, 2024
Contract Type FiledApril 10th, 2024This Settlement Agreement is entered into by and between Candy Molinari and Mikhail Kholyusev (“Plaintiffs”), individually and on behalf of the Settlement Class (as defined below), by and through Settlement Class Counsel (as defined below), and Defendant Welfare & Pension Administration Service, Inc. (“WPAS” or “Defendant”), in order to effect a full and final settlement and dismissal with prejudice of all claims against WPAS alleged in the above-captioned litigation on the terms set forth below and to the full extent reflected herein. Plaintiffs and WPAS are referred to collectively herein as the “Parties” and individually as a “Party.”