SETTLEMENT AND RELEASE AGREEMENTSettlement and Release Agreement • July 2nd, 2024
Contract Type FiledJuly 2nd, 2024This Settlement and Release Agreement, dated as of June 13, 2024, is made and entered into by and among the following “Settling Parties” (as defined below): Deborah Cimino and Conor Mancone (collectively, “Plaintiffs”), individually and on behalf of the “Settlement Class” (as defined below), by and through their counsel of record (“Proposed Settlement Class Counsel,” as defined below), and ETZ Hayim Holdings, S.P.C. d/b/a Lazarus Naturals (“ETZ” or “Defendant”) (together with Plaintiffs, the “Parties”), by and through its counsel of record, Jackson Biesecker and Anthony Copple of Jackson Lewis P.C. This Settlement is subject to Court approval and is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the “Released Claims” (as defined below), upon and subject to the terms and conditions hereof.