CLASS ACTION SETTLEMENT AGREEMENT AND RELEASEClass Action Settlement Agreement • December 27th, 2019 • California
Contract Type FiledDecember 27th, 2019 JurisdictionAgreement”) is entered into by and between Plaintiff Donald Lusnak (“Settlement Class Representative”), on behalf of himself and the putative Settlement Class (as defined below), on the one hand, and Defendant Bank of America, N.A. (“Bank of America”) (collectively referred to as the “Parties”). This Settlement Agreement is conditioned upon and subject to approval of the Court as required by Rule 23 of the Federal Rules of Civil Procedure. Settlement Class Counsel (as defined below) and the Parties hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Settlement Agreement and upon the Effective Date (as defined below), the Lawsuit (as defined below) and all Released Claims (as defined below) shall be finally and fully settled, compromised, and released, on the following terms and conditions: