Common Contracts

SETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • September 30th, 2019 • Florida

• Contract Type
  Settlement Agreement
• Filed
  September 30th, 2019
• Jurisdiction
  Florida

This Settlement Agreement and Release is entered into between and among Carlos Guarisma (“Plaintiff” or “Guarisma”), Lori Zaragoza (“Zaragoza”) and Lani Woods (“Woods”) on behalf of themselves and the Settlement Class (as hereinafter defined), and Defendant Alpargatas USA, Inc., d/b/a Havaianas (“Defendant”) (collectively, the “Parties”). As provided herein, this Agreement fully and finally compromises and settles any and all claims for any alleged violation of the Fair and Accurate Credit Transactions Act, 15 U.S.C. §§ 1681 et seq., (“FACTA”), and any and all claims that were or could have been asserted based on the facts alleged in the lawsuit styled Carlos Guarisma v. Alpargatas USA, Inc. d/b/a Havaianas, Case No. 1:18-cv-24351 (the “Litigation”), in any forum.