SETTLEMENT AGREEMENTSettlement Agreement • December 5th, 2022 • New Jersey
Contract Type FiledDecember 5th, 2022 JurisdictionThis Settlement Agreement (this “Agreement” or “Settlement Agreement”) sets forth the terms of the settlement of claims by and between Kim Payton-Fernandez, the named plaintiff (“Payton-Fernandez”) in Kim Payton-Fernandez v. Burlington Stores, Inc., et al., Civil Action No. 1:22-cv-00608 (the “Lawsuit”), which is pending in the United States District Court for the District of New Jersey (the “Court”), the Participating Collective Members (as defined below), Lavern Coleman (an opt-in who is to be added as a named plaintiff in the Lawsuit), Darniel Williams (an opt-in who is to be added as a named plaintiff in the Lawsuit), and Defendants Burlington Stores, Inc., Burlington Coat Factory Warehouse Corporation, Burlington Coat Factory Investments Holdings, Inc., and Burlington Coat Factory Holdings, LLC (together “Burlington”) (all collectively referred to as the “Parties”).