SETTLEMENT AGREEMENTSettlement Agreement • April 20th, 2021 • New York
Contract Type FiledApril 20th, 2021 JurisdictionSubject to the approval of the Court and pursuant to Rule 23 of the Federal Rules of Civil Procedure, this Class Action Settlement Agreement and Release, including the attached Exhibits (“Settlement Agreement”), is entered into between Plaintiffs Lauren Biegel (“Biegel”), Greg Maroney (“Maroney”), Stephen Bradshaw (“Bradshaw”), Angela Farve (“Farve”), Ryan Cosgrove (“Cosgrove”), Clive Rhoden (“Rhoden”), and Christina Henderson (“Henderson”) (collectively, the “Plaintiffs”), on behalf of themselves and on behalf of those similarly situated, hereinafter the Settlement Class Members, and Defendant Blue Diamond Growers (“BDG” or the “Company”). Plaintiffs and BDG are collectively referred to as “the Parties.”