SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • September 17th, 2018 • Ohio
Contract Type FiledSeptember 17th, 2018 JurisdictionThis Settlement Agreement and Release of Claims, along with all exhibits hereto (collectively, the “Settlement Agreement”) is entered into by and between Cuyahoga County, and, Gary C. Fitzpatrick, Sr. (“Named Plaintiff”) and all current and former Cuyahoga County hourly employees who opted-into the litigation (“Opt-In Plaintiffs”) in the case of Gary C. Fitzpatrick, Sr. et al. v. Cuyahoga County, Case No. 1:17-CV-01235, in the United States District Court for the Northern District of Ohio (the “Lawsuit”). The Named Plaintiffs and Opt-in Plaintiffs will collectively be referred to as the “Plaintiffs.” Plaintiffs and Cuyahoga County will be collectively referred to as the “Parties.”