Common Contracts
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SETTLEMENT AGREEMENT BETWEEN PLAINTIFFS AND THE CORDELL DEFENDANTS FOR WAVE IV IN SETTLEMENTSDecember 2nd, 2011
Putative Class Representatives Anita Hunter, Johnna Bozzo (also known as Johnna Bozza), Celltex Site Services, Ltd., Grande Investment, LLC, Quirk Infiniti, Inc., Michael Whitton, and Sadi Suhweil (collectively, the "Class Representatives"), on behalf of themselves and the putative Class in the action captioned Hunter, et al. v. Citibank, NA., et al, No. 09-CV-02079-JW (N.D. Cal.), and the “Cordell Defendants”1 (collectively referred to as the "Parties"), enter into this stipulation and agreement of settlement (the "Agreement" or "Settlement Agreement"). This Agreement is intended by the Parties hereto to fully, finally, completely, and unconditionally compromise, resolve, forever discharge, release, acquit, waive, dismiss with prejudice and settle the Released Claims (as defined herein), subject to the terms and conditions set forth below and final approval by the Class Action Court (as defined herein). Gerard A. McHale, Jr., as Trustee for The 1031 Debtors Liquidation Trust (the "103
