DEREK VOLKMAN, on behalf of himself and all others similarly situated,Plaintiff, vs. Case No. 1:18-cv-00091-WCG ENHANCED RECOVERY COMPANY,LLC, a Delaware Limited Liability Company, d/b/a ERC,Defendants. CLASS SETTLEMENT AGREEMENTClass Settlement Agreement • September 23rd, 2020
Contract Type FiledSeptember 23rd, 2020This Class Settlement Agreement dated as of September 23, 2020, (“Agreement”), is made and entered into by and among the following Parties: (i) Plaintiff, Derek Volkman, individually and on behalf of certified Class Members, by and through Class Counsel; and (ii) Defendant, Enhanced Recovery Company, LLC d/b/a ERC (“ERC”), by and through its counsel of record in this Litigation.1 Plaintiff and ERC are collectively referred to as the “Parties.” The Parties intend for this Agreement to fully, finally, and forever resolve, discharge, and settle all released rights and claims, as set forth below, subject to the terms and conditions set forth herein.