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Contract Type FiledMarch 3rd, 2023 JurisdictionThis Settlement Agreement and Release (Agreement) is made and entered into by and among Defendant Safeway, Inc., (Defendant) and Plaintiffs Pauline Long and Marsha Hayes (Plaintiffs), on their own behalf and on behalf of a putative class and each of its Settlement Class Members (as defined herein) in Long, et al. v. Safeway, Inc., Multnomah County Circuit Court Case No. 19CV45421 (the Action) with the assistance of counsel. Plaintiffs and Defendant collectively are referred to in this Agreement as the Parties. The Parties agree that the Action and the Released Claims (as defined herein) shall be fully and finally compromised, settled and released, and dismissed with prejudice and/or final judgment entered, subject to the approval of the Court and the terms and provisions set forth in this Agreement.