STIPULATION OF AGREEMENT AND SETTLEMENT AND RELEASEStipulation of Agreement and Settlement and Release • May 19th, 2023 • California
Contract Type FiledMay 19th, 2023 JurisdictionThis Stipulation of Agreement and Settlement and Release is entered into by and among the Named Plaintiff (as defined below), for himself and on behalf of the Settlement Class, and Defendant Dave Inc. (“Dave” or “Defendant”), subject to preliminary and final Court approval as required by California Rule of Court 3.769. As provided herein, Defendant and the Named Plaintiff hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against the Defendant in connection with the Data Breach (defined below) as alleged in the action titled Stoffers v. Dave Inc., Case No. 20STCV35381 (LA Superior Court) shall be settled and compromised upon the terms and conditions contained herein. The Named Plaintiff and Defendant are collectively referred to herein as the “Parties.”