Common Contracts

STIPULATION OF SETTLEMENT

Settlement Agreement • April 25th, 2021 • California

• Contract Type
  Settlement Agreement
• Filed
  April 25th, 2021
• Jurisdiction
  California

This Stipulation of Settlement (“Settlement Agreement”) is reached by and between Plaintiff Bernardo Santos aka Bernardo Santos Romero, Bernardo Romero, and Julio Garay (“Plaintiff”), individually and on behalf of all members of the Settlement Class (defined below), on one hand, and Torres Farm Labor Contractor, Inc. (“Defendant”), on the other hand. Plaintiff and Defendant are referred to herein collectively as the “Parties.” Plaintiff and the Settlement Class are represented by Paul K. Haines of Haines Law Group, APC and Scott M. Lidman, Elizabeth Nguyen, Milan Moore, and Romina Tamiry of Lidman Law, APC (collectively, “Class Counsel”). Defendant is represented by Thomas P. Feher of Lebeau Thelen LLP.