SETTLEMENT AGREEMENT, RELEASE, and WAIVERSettlement Agreement • September 13th, 2013 • New York
Contract Type FiledSeptember 13th, 2013 JurisdictionThis Settlement Agreement, Release and Waiver (“Agreement”) is made this 13th day of September, 2013, by and between Plaintiff Ellen Ogaian (“Ogaian” or “Plaintiff”), Opt-In Mario Garrido, (“Garrido” or “Opt-In”) on behalf of themselves, the class and subclasses they purport to represent, their agents, representatives, assignees, heirs, executors, beneficiaries and trustees (collectively, “Plaintiffs”) and Christmas Tree Shops, Inc., (referred to herein as “CTS”), on behalf of itself, its parents, (including without limitation, Bed Bath and Beyond Inc.,) divisions, subsidiaries, predecessors and successors, and their directors, officers, members, fiduciaries, insurers, employees, attorneys and agents (each in their individual and corporate capacities) (collectively the “Released Parties”) (CTS, Plaintiffs and the Opt-In, are collectively referred to herein as the “Parties”).