Common Contracts

STIPULATION OF SETTLEMENT AND RELEASE

Settlement Agreement • February 25th, 2016

• Contract Type
  Settlement Agreement
• Filed
  February 25th, 2016

This stipulation of settlement and release (“Stipulation of Settlement”) is made and entered into by and between plaintiff Daniel Fredrick and Marvin Merklin (“Plaintiffs” or “Class Representatives”), individually and on behalf of all others similarly situated, and defendants ACE Security Systems, Inc., d/b/a/ ASC Security USA and Mark Sessa (“Defendants”), and their respective counsel of record, subject to the terms and conditions hereof and the Court’s approval. This Stipulation of Settlement is a global resolution which, subject to Court approval, is intended to be a full and final resolution of both Plaintiff’s class and individual claims, pending in the Riverside County Superior Court.