SETTLEMENT AGREEMENTSettlement Agreement • March 1st, 2023
Contract Type FiledMarch 1st, 2023This Settlement Agreement is made and entered into by and between Plaintiffs Gilmer Bautista, Gilmer’s Enterprise LLC, Juan Mendoza, Alejandro Diaz, and Tyler Witter (“Plaintiffs” or “Settlement Class Representatives”), for themselves and the Settlement Class Members (as defined below) and Corali Lopez-Castro, as the Court-appointed Receiver for MJ Capital Funding LLC, MJ Taxes and More Inc., Pavel Ruiz MJCF LLC, and UDM Remodeling, LLC (“Receiver” or “Settlement Administrator”) on the one hand, and Wells Fargo Bank, N.A., the Defendant (as defined below) on the other hand. Plaintiffs, Defendant, and Receiver are each a “Party” to this Settlement Agreement. The Plaintiffs and Defendant are referred to collectively herein as the “Parties,” and the Plaintiffs, Defendant and Receiver are referred to collectively herein as the “Global Parties.”