SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • January 18th, 2018 • Ohio
Contract Type FiledJanuary 18th, 2018 JurisdictionThis Settlement Agreement and Release (“Settlement Agreement”) is made and entered into by and between (1) Plaintiffs Kenneth Chapman, Jessica Vennel, Jason Jackson and Edwina Pinon (collectively, “Plaintiffs”; each a “Plaintiff’), on behalf of themselves individually and as representatives of the proposed Settlement Class (defined below); and (2) Defendant Tristar Products, Inc. (“Tristar” or “Defendant”), on its own behalf and for the benefit of the Released Parties. Plaintiffs and Tristar are collectively referred to as the “Parties,” each of which is a “Party.” This Settlement Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle all released rights and claims to the extent set forth below, subject to the terms and conditions set forth herein.