Common Contracts

SETTLEMENT AGREEMENT AND RELEASE

Settlement Agreement • October 24th, 2022 • Delaware

• Contract Type
  Settlement Agreement
• Filed
  October 24th, 2022
• Jurisdiction
  Delaware

This Settlement Agreement and Release (the “Agreement”) is made and entered into this 24th day of October, 2022, by and among (1) Plaintiffs1, individually and on behalf of the Settlement Class; and (2) TD Bank, N.A. (“TD Bank”), subject to preliminary and final Court approval as required by Rule 23(e) of the Federal Rules of Civil Procedure. As provided herein, TD Bank, Class Counsel, and Plaintiffs hereby stipulate and 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, all claims of the Settlement Class against TD Bank in the action titled Galgano d/b/a Shear Envy Hair Studio, et al. v. TD Bank, N.A., Case No. 1:20-cv-05623 (D.N.J.) (the “Action”), shall be settled and compromised upon the terms and conditions contained herein.