STIPULATION OF SETTLEMENTSettlement Agreement • September 23rd, 2020
Contract Type FiledSeptember 23rd, 2020This Stipulation of Settlement (“Settlement Agreement” or “Settlement”) is reached by and between Plaintiff Victor Pelaez (“Plaintiff,” or the “Class Representative”), individually and on behalf of all members of the Settlement Class (defined below), and Defendants Los Angeles Recycling Center, Inc., Bestway Recycling Company, Inc., Bestway Global Holdings, Inc., Western Recycling, Inc., and Bestway Recycling of Pomona, Inc. (collectively, “Defendants”) (Plaintiff and Defendants 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 Sam Sani of Sani Law, APC (“Class Counsel”). Defendants are represented by Jeffrey P. Fuchsman of Ballard Rosenberg Golper & Savitt LLP.