STIPULATION OF AGREEMENT AND SETTLEMENT AND RELEASESettlement Agreement • July 23rd, 2020 • California
Contract Type FiledJuly 23rd, 2020 JurisdictionThis Stipulation of Agreement and Settlement and Release is entered into by and among the Named Plaintiffs (as defined below), for themselves and on behalf of the Settlement Class, and Defendant Activehours, Inc. d/b/a Earnin (“Earnin” or “Defendant”), subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Defendant and the Named 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 of the Settlement Class against the Defendant as alleged in the complaint filed in the action titled Perks, et al, v. Activehours, Inc. d/b/a Earnin, Case No. 5:19-cv-05543-BLF (N.D. Cal.) shall be settled and compromised upon the terms and conditions contained herein. The Named Plaintiffs and Defendant are collectively referred to herein as the “Parties.”