CLASS AND REPRESENTATIVE ACTION SETTLEMENT AGREEMENTClass and Representative Action Settlement Agreement • July 20th, 2023 • California
Contract Type FiledJuly 20th, 2023 JurisdictionThis Class and Representative Action Settlement Agreement ( Settlement Agreement ) is made and entered into between Plaintiff Rodney Albert Jordan ( Plaintiff or Class Representative ) on the one hand, individually and on behalf of the Settlement Class and PAGA Members (as defined below), and Defendant The Martin-Brower Company, L.L.C. ( Defendant ) on the other hand, subject to the approval of the Court, as provided below. This Settlement Agreement is intended by Plaintiff and Defendant to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined below), upon and subject to the terms and conditions herein, as follows: