Common Contracts

SETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • March 31st, 2014 • New York

• Contract Type
  Settlement Agreement
• Filed
  March 31st, 2014
• Jurisdiction
  New York

This Settlement Agreement and Release, including all exhibits hereto (collectively, the “Agreement”) is entered into by named plaintiff Galina Padilla (“Padilla” or the “Named Plaintiff”) and opt-in Jacob Rabago (the “Additional Plaintiff” and, together with the Named Plaintiff, “Plaintiffs”) individually and on behalf of a class of individuals they seek to represent (as defined herein) and by Class Counsel, as defined herein, and by Defendant Etro U.S.A., Inc. (“Etro” or the “Defendant” and, together with Plaintiffs, the “Parties”).