SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • September 2nd, 2018 • Texas
Contract Type FiledSeptember 2nd, 2018 Jurisdictionday of September, 2018, by and among (1) Plaintiffs Al’s Pals Pet Care, LLC, DeFabio Spine and Sports Rehab, LLC, Julie Rudiger, Inc., Mena Stone & Landscaping Supplies, LLC, Tulsa Art Center, LLC, Ban-A-Pest Extermination Co., Inc., Fleetwood Chiropractic & Rehabilitation, PC, and Bayley Products, Inc., for themselves and on behalf of the Settlement Class, and (2) Defendants Woodforest National Bank and Paysafe Payment Processing Solutions, LLC, subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. The Parties hereby 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 after Final Approval and payment of the Settlement Amount, all claims of the Settlement Class against Defendants in the action titled Al’s Pals Pet Care, LLC, et al. v. Woodforest National Bank, N.A., et al., S.D. Tex. Case No. 4:17-CV-3852 (the “Action”), shall be settled