STIPULATION OF CLASS ACTION AND PAGA SETTLEMENTSettlement Agreement • December 6th, 2022
Contract Type FiledDecember 6th, 2022This Stipulation of Settlement (“Settlement Agreement”) is reached by and between Plaintiff Magali Martinez (“Plaintiff”), individually and on behalf of all members of the Settlement Class and PAGA Employees (both terms defined below), on the one hand, and Defendant Ready Roast Nut Company, L.L.C. (“Defendant”), on the other hand. Plaintiff and Defendant are referred to herein collectively as the “Parties.” Plaintiff, the Settlement Class and the PAGA Employees are represented by Paul K. Haines of Haines Law Group, APC and Scott M. Lidman, Elizabeth Nguyen, and Milan Moore of Lidman Law, APC (collectively, “Class Counsel”). Defendant is represented by Susan K. Hatmaker of Hatmaker Law Group.