SETTLEMENT AND RELEASE AGREEMENTSettlement and Release Agreement • November 26th, 2024
Contract Type FiledNovember 26th, 2024This Settlement and Release Agreement (“Agreement” or “Settlement Agreement”) is entered into by and between Progressive Casualty Insurance Company (“Progressive” or “Defendant”), and Kenneth Okonski, Bradley Okonski, Edward Reis, Tosif Khan, Kulsoom Tosif, Eduardo Barbosa, Rebecca Johnson, Stephen Johnson, Roxanne Trigg, Giovanni Madaffari, and Dodie Waden (“Plaintiffs”), both individually and on behalf of the Settlement Class, in the case of Kenneth Okonski, et al. v. Progressive Casualty Insurance Company, Case No. 1:23-cv-01548- PAG, currently pending in the United States District Court for Northern District of Ohio. Defendant and Plaintiffs are each referred to as a “Party” and are collectively referred to herein as “the Parties.”