STIPULATION AND SETTLEMENT AGREEMENT AMONG PLAINTIFFS DONALD KOESTER, JOHN CHASE, EARNEST LEE, CHARLES McCALEB a/k/a CHARLES SMITH, AND FRED COLBY, INDIVIDUALLY AND ON BEHALF OF A SETTLEMENT CLASS, AND DEFENDANTS USAA GENERAL INDEMNITY COMPANY, UNITED...Stipulation and Settlement Agreement • April 22nd, 2020
Contract Type FiledApril 22nd, 2020IT IS HEREBY STIPULATED AND AGREED, by and among Plaintiffs Donald Koester, John Chase, Earnest Lee, Charles McCaleb a/k/a Charles Smith, and Fred Colby, individually and on behalf of themselves and the Settlement Class as defined herein, and Defendants United Services Automobile Association (“USAA”), USAA Casualty Insurance Company (“USAA CIC”), USAA General Indemnity Company (“USAA GIC”) and Garrison Property and Casualty Insurance Company (“Garrison”) (collectively, “Defendants”), that, in consideration of the promises and covenants set forth in this Stipulation and Settlement Agreement (“Agreement”) and, upon entry by the Court of an order of Final Judgment in the lawsuit captioned Koester v. USAA General Indemnity Company, No. 2:19-cv-2283 (“Action”), and the matters raised by, or which could have been raised by, Representative Plaintiffs in the Action against Defendants are settled, compromised, and dismissed on the merits and with prejudice on the terms and conditions set forth