STIPULATION OF CLASS ACTION AND PAGA SETTLEMENTStipulation of Class Action and Paga Settlement • September 13th, 2022
Contract Type FiledSeptember 13th, 2022This Stipulation of Settlement (“Settlement Agreement”) is reached by and between Plaintiff Julio Machado (“Plaintiff”), individually and on behalf of all members of the Settlement Class and PAGA Employees (both terms defined below), on one hand, and Defendant Pacific Drayage services, LLC (“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 Jaime B. Laurent of Littler Mendelson, P.C.