SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • December 18th, 2015 • California
Contract Type FiledDecember 18th, 2015 JurisdictionThis Settlement Agreement and Release (the “Settlement Agreement”), effective as of the date of the last signature below, is made by and between Plaintiff Paul Stemple (“Stemple”), individually and on behalf of the class of the Settlement Class as further defined herein, and Defendant QC Holdings, Inc. (“QC”) (the “Parties”), subject to Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Class Counsel and the Parties hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Settlement Agreement and upon entry by the Court of a Final Approval Order and Final Judgment, all claims of the Settlement Class against QC consistent with the TCPA claims asserted in Paul Stemple, individually and on behalf of all others similarly situated, v. QC Holdings, Inc., Case No. 12-cv-01997-BAS-WVG, (the “Action”) pending before the United States District Court for the Southern District of California, shall be settled a