Common Contracts

SETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • June 29th, 2016

• Contract Type
  Settlement Agreement
• Filed
  June 29th, 2016

This Settlement Agreement and Release (the “Agreement”) is made by and among Jennifer Ossola and Scott Dolemba (together, “Plaintiffs”), on behalf of themselves and the Settlement Class (as defined below), on the one hand, and American Express Company and American Express Centurion Bank (together, “American Express”), and West Asset Management, Inc. (“WAM”) (together with American Express, “Defendants”), on the other hand. Plaintiffs, Class Counsel (as defined below) and American Express hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court (as defined below) of a Final Approval Order (as defined below), all claims of Plaintiffs and the Settlement Class Members (as defined below) in the action entitled Jennifer Ossola, Joetta Callentine and Scott Dolemba v. American Express Company, et al., U.S.D.C. Northern District of Illinois, Case No. 1:13-CV-4836 (the “Action”), shall be settled, compromised and rele