SETTLEMENT AGREEMENT AND RELEASESettlement Agreement and Release • July 26th, 2021 • New York
Contract Type FiledJuly 26th, 2021 JurisdictionThis Settlement Agreement and Release (“Agreement”) is made as of April 23, 2021, by and between, as hereinafter defined, (a) Settlement Class Representatives on behalf of themselves and the Settlement Class, and (b) Hudson’s Bay Company ULC (formerly known as Hudson’s Bay Company) (“HBC”), Saks Fifth Avenue LLC, Saks & Company LLC, and Saks Incorporated (collectively, “Saks”), and Lord & Taylor, LLC (“Lord & Taylor”) (collectively, “Hudson’s Bay” or “Defendants”), and subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. Settlement Class Representatives and Hudson’s Bay enter into this Agreement by and through their respective counsel. By this Agreement, Hudson’s Bay and Settlement Class Representatives seek to and do hereby resolve all claims of the Settlement Class Representatives and the Settlement Class (as defined in this Agreement) that could have been or were asserted in the action titled Arkansas Federal Credit Union an