SECOND AMENDED SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • December 23rd, 2019 • California
Contract Type FiledDecember 23rd, 2019 JurisdictionThis Settlement Agreement and Release (“Agreement”) is made and entered into this 18th day of December 2019, by and among (1) Plaintiffs, Roger Harris, Duane Brown, Brian Lindsey (“Plaintiffs”), individually, and on behalf of the Settlement Class, and (2) Farmers Insurance Exchange and Mid Century Insurance Company (collectively “Farmers” or “Defendants”), subject to preliminary and final approval as required by the California Rules of Court. As provided herein, Plaintiffs, Class Counsel and Farmers 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 and achievement of the Effective Date all claims of the Settlement Class against Farmers in the action titled Harris, et al. v. Farmers Insurance Exchange, et al., Superior Court of California, County of Los Angeles, Case No. BC 57948 (“Action”), shall be settled and compromised upon the terms and conditions contained herein.