CLASS SETTLEMENT AGREEMENT AND RELEASEClass Settlement Agreement • July 20th, 2023
Contract Type FiledJuly 20th, 2023This Class Settlement Agreement and Release (“Class Settlement Agreement”) is made and entered into by and among the following Settling Parties as defined below: (a) Plaintiff Jami Zucchero (“Representative Plaintiff”), individually and on behalf of the Settlement Class (as defined below), by and through her counsel Scott Edward Cole, Laura Van Note and Cody Alexander Bolce of Cole & Van Note (“Representative Plaintiff’s Counsel”) and (b) Defendant Heirloom Roses, Inc. (“Defendant” or “Heirloom”), by and through its counsel, Spencer Persson and Jean M. Fundakowski of Davis Wright Tremaine LLP (“Defendant’s Counsel”). The Class Settlement Agreement is subject to Court approval and is intended by the Settling Parties to resolve, discharge and settle the Released Claims (as defined below), upon and subject to the terms and conditions hereof fully, finally and forever.