SETTLEMENT AGREEMENT AND RELEASESettlement Agreement and Release • September 17th, 2020 • New York
Contract Type FiledSeptember 17th, 2020 Jurisdictionand any possible appeals. They have taken into account the uncertainty and risk of the outcome of further litigation, and the difficulties and delays inherent in such litigation. They are also aware of the burdens of proof necessary to establish liability and damages for the claims alleged in the Action and the defenses thereto. Based upon their evaluation, the Class Representative and Class Counsel have determined that the settlement set forth in the Agreement is in the best interests of the Class Representative and the Settlement Class and is fair, adequate, and reasonable.