Settlement Agreement and ReleaseSettlement Agreement and Release • October 6th, 2022 • Missouri
Contract Type FiledOctober 6th, 2022 JurisdictionThis Settlement Agreement and Release (“Settlement” or “Agreement”),1 dated as of the date of last signature for this Agreement, is entered into between Plaintiffs Zachariah Hall and Cheryl Hinds-Thomas (collectively, “Plaintiffs”), individually and on behalf of the Settlement Class (as defined in ¶ 42 below), and Defendants Safeco Insurance Company of Illinois (“Safeco”) and LM General Insurance Company (“LM General”) (collectively, “Defendants”). Plaintiffs and Defendants are each individually a “Party” and are collectively the “Parties.” The Parties hereby agree to the following terms in full settlement of the Action, subject to Final Approval, as defined below.