SETTLEMENT AGREEEMENT AND RELEASESettlement Agreement • November 19th, 2019 • New York
Contract Type FiledNovember 19th, 2019 JurisdictionThis Settlement Agreement and Release (the “Agreement”) is entered into by and between Robert Bryant, Trinton Hatton, and Marc Meeters (“Named Plaintiffs”), individually and on behalf of Assistant Managers (“AMs”) employed by Potbelly Corporation and paid as exempt who opted into the Litigation and were employed in the United States from October 5, 2014 through January 28, 2018, and Assistant Managers employed in Illinois from October 5, 2014 to January 28, 2018 and paid as exempt, both excluding any Assistant Manager paid as exempt (“AM”) who released all claims during the Class Period as part of a settlement in the case entitled Chiu v. Potbelly Corporation, or AMs who participated in the Chiu settlement, and were not employed after the release date in Chiu (December 1, 2016) (collectively “Plaintiffs”), and Defendant Potbelly Sandwich Works, LLC (“Potbelly” or “Defendant”) (together with Plaintiffs, the “Parties”).