Common Contracts

SETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • April 17th, 2023 • Delaware

• Contract Type
  Settlement Agreement
• Filed
  April 17th, 2023
• Jurisdiction
  Delaware

This Settlement Agreement and Release (“Agreement”) is made and entered into this 27th day of March 2023, by and among (1) Plaintiffs (as defined below), for themselves and, as to Class Representative Judith Jimenez, on behalf of the Settlement Class (as defined below); and (2) TD Bank, N.A. (“TD Bank”), subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, TD Bank, Class Counsel (as defined below), and Plaintiffs 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 against TD Bank in the action titled Judith Jimenez, et al. v. TD Bank, N.A., D.N.J., Civil Action No. 1:20-cv-07699 (“Jimenez” or the “Action”), including the claims of the Settlement Class, shall be settled and compromised upon the terms and conditions contained herein.