PROPOSED SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • April 9th, 2018
Contract Type FiledApril 9th, 2018Plaintiffs Keith Cole, Jackie Brannum, Richard Elvin King, Fred Wallace, Michael Denton, and Marvin Ray Yates, individually and on behalf of those similar situated, and Defendants Bryan Collier in his official capacity, Robert Herrera in his official capacity, and the Texas Department of Criminal Justice (TDCJ), enter into this Settlement Agreement and Release (Settlement Agreement”), subject to the approval of the Court. The Parties, in consideration of the mutual promises, agreements, and covenants contained herein, the sufficiency and receipt of which are hereby acknowledged, stipulate and agree as follows: