CLASS AND COLLECTIVE ACTION SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • June 8th, 2023
Contract Type FiledJune 8th, 2023Subject to the approval of the Court and pursuant to Rule 23 of the Federal Rules of Civil Procedure and § 216(b) of the Fair Labor Standards Act (“FLSA”), this Class and Collective Action Settlement Agreement and Release (“Settlement Agreement”), including the attached Exhibits, is entered into between: (a) Named Plaintiff Deborah Pike (referred to alternatively herein as “Class Representative,” “Plaintiff,” or “Named Plaintiff”), on behalf of herself and on behalf of each Settlement Class Member; and (b) HCF Management, Inc. (“HCF” or “Defendant”).1 As provided below, the Parties hereby stipulate and agree that, in consideration of the promises and covenants set forth herein and upon the Effective Date, this Settlement Agreement is intended by the Parties to, and shall, fully and finally compromise, resolve, discharge, release, and settle the Released Claims and to dismiss these Actions, subject to the Court’s approval and to the terms and conditions set forth below, and without any