SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • August 17th, 2021
Contract Type FiledAugust 17th, 2021This Settlement Agreement and Release (the “Agreement”) is entered into by and among Defendant Pepperidge Farm, Incorporated (“Pepperidge Farm”) and Plaintiffs Douglas Brett, Terrence Fox, Steven Pulford and Mark Ryan (the “Named Plaintiffs”) and the class of individuals that Named Plaintiffs seek to represent for settlement purposes only. This Agreement is the further long form settlement agreement contemplated in section 19 of the Memorandum of Understanding entered into between Pepperidge Farm and the Named Plaintiffs, by their counsel, on or about April 16, 2021. Named Plaintiffs, Class Counsel, and Pepperidge Farm hereby stipulate and agree that, in consideration of the promises and covenants as set forth in this Agreement and upon entry by the Court of a Final Order and Judgment, all claims of the Named Plaintiffs and the Qualified Class Members in the Actions shall be settled, compromised, and released upon the terms and conditions contained herein.1