DOCUMENT PREPAREDSettlement Agreement • March 12th, 2021 • California
Contract Type FiledMarch 12th, 2021 Jurisdictiondocumentation. Plaintiff believes that the claims asserted in the SAC have merit. Defendant believes that the causes of action asserted in the Complaint are without merit and that Defendant has a complete defenses thereto. Class Counsel (as defined below) and Defendant’s Counsel (as defined below) have engaged in extensive arm’s length negotiations in reaching this Settlement Agreement. All Parties and their counsel believe the settlement terms are fair and reasonable to the Class (as defined below). Plaintiff and Class Counsel believe that the proposed settlement set forth in this Settlement Agreement confers substantial benefits upon the Class and each of its members. Based on their evaluation, the Plaintiff and Class Counsel have determined that the proposed settlement set forth in the Settlement Agreement is in the best interests of the Class.