SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • March 30th, 2020 • New York
Contract Type FiledMarch 30th, 2020 JurisdictionThis Settlement Agreement and Release (“Agreement”) is made and entered into this 15th day of March, 2019, by and among: (1) Plaintiff, Chris Lashambae, individually and on behalf of the Settlement Class as defined herein; and (2) Capital One, N.A. (“Capital One” or the “Bank”). As provided herein, Plaintiff, Class Counsel, and Capital One hereby agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a Final Approval Order, all claims of Plaintiff and the Settlement Class Members, as defined below, against Capital One in the action titled Lashambae v. Capital One Bank, N.A., No. 1:17-cv-06406 (E.D.N.Y.) (the “Action”) shall be settled and compromised upon the terms and conditions contained herein.