SETTLEMENT AGREEMENTSettlement Agreement • October 23rd, 2023
Contract Type FiledOctober 23rd, 2023This Settlement Agreement (the “Settlement Agreement” or the “Agreement”) is made and entered into as of this 13th day of October, 2023, by and between Plaintiffs Matthew Opheim, Greta Opela, Kia Holyfield, Kenneth Eldridge, Carl Popolo, Ken Barton, Matthew Kieran Byrne, William Hendra, Madelen Tejada, Melissa Gallo, Saara Massahood, Robert Mills, Ivan Cugel, Kathy Madore, Kelley Morgan, and Michelle Vargas (“Plaintiffs”), individually and as representatives of the Settlement Class defined below, and Volkswagen Group of America, Inc. (“VWGoA” or “Defendant”) (collectively, the “Parties”).