SETTLEMENT AGREEMENT AND RELEASESettlement Agreement and Release • April 9th, 2021 • New York
Contract Type FiledApril 9th, 2021 JurisdictionThis Settlement Agreement and Release (the “Agreement”) is made and entered into on this 9th day of April, 2021, by and among (1) Plaintiffs (as defined below), individually and on behalf of the Settlement Class (as defined below); and Chase (as defined below), subject to Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Plaintiffs, Settlement Class Counsel (as defined below), and Chase hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon the occurrence of the Effective Date (as defined herein), all claims of the Participating Settlement Class Members against Chase in the action titled Cymbalista v. JPMorgan Chase Bank, N.A., Case No. 2:20-cv-00456 (E.D.N.Y.) (the “Action” or “Lawsuit”), shall be settled and compromised upon the terms and conditions contained herein.