SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • November 1st, 2019 • Florida
Contract Type FiledNovember 1st, 2019 JurisdictionThis Settlement Agreement and Release (“Agreement”) is entered into between and among the following parties (the “Parties”), by and through their respective counsel: Brian (“Keim” or “Class Representative” or “Named Plaintiff”), on behalf of himself and the Settlement Class (as hereinafter defined), and ADF Midatlantic, LLC, American Huts Inc., ADF Pizza I, LLC, ADF PA, LLC (collectively, the “Franchise Defendants”) and Pizza Hut, LLC, (“Pizza Hut,” and collectively with the Franchise Defendants, “Defendants”). This Agreement fully and finally compromises and settles any and all claims that were or could have been asserted in the lawsuit styled as Keim v. ADF Midatlantic LLC et al, Case No. 9:12-cv-80577-KAM (S.D. Fla.) (“Litigation”) and all claims that relate to or arise out of the Franchise Defendants allegedly sending automated text messages to individuals’ cell phones without consent during the Settlement Class Period, including all claims under the Telephone Consumer Protection A