Common Contracts

SETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • September 11th, 2013 • Delaware

• Contract Type
  Settlement Agreement
• Filed
  September 11th, 2013
• Jurisdiction
  Delaware

This Settlement Agreement and Release (the “Agreement” or “Settlement”) is made by and among plaintiffs Walter Bradley and Andrew Steinfeld (each individually, “Plaintiff”; collectively, “Plaintiffs”), on behalf of themselves and the Settlement Class (as defined below), on the one hand, and Discover Financial Services, DFS Services LLC and Discover Bank, on behalf of themselves and their affiliates or subsidiaries (collectively, “Discover”), on the other hand. Discover, Settlement 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 (as defined below) of a Final Approval Order (as defined below), all claims of Plaintiffs and the Settlement Class Members (as defined below) against Discover in the actions entitled Walter Bradley v. Discover Financial Services, U.S.D.C., Northern District of California Case No. 4:11-cv-5746-YGR (“Bradley”), and Andrew Steinfel