Common Contracts

SETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • May 29th, 2020 • Delaware

• Contract Type
  Settlement Agreement
• Filed
  May 29th, 2020
• Jurisdiction
  Delaware

This Settlement Agreement and Release (the “Agreement”) is made and entered into this 22nd day of May, 2020, by and among (1) Plaintiffs (as defined below), individually and on behalf of the Settlement Class (as defined below); and (2) Defendant (as defined below), subject to Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Plaintiffs, Class Counsel (as defined below), and Defendant hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the United States District Court for the Southern District of New York of a Final Approval Order, all claims of the Settlement Class against Defendant in the action titled Tucker v. Chase Bank USA, N.A., Case No. 1:18-cv-03155 (S.D.N.Y.) (the “Action”), shall be settled and compromised upon the terms and conditions contained herein.