SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • March 18th, 2020 • Virginia
Contract Type FiledMarch 18th, 2020 JurisdictionThis Settlement Agreement and Release (“Agreement”) is made and entered into this 11th day of March, 2020, by and among (1) Plaintiff (as defined below), for himself and on behalf of the Settlement Class (as defined below), and (2) Defendant (as defined below), subject to Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Plaintiff and Defendant hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a Final Order and Judgment, all claims of the Settlement Class against Defendant in the action titled Hawkins v.