CLASS ACTION SETTLEMENT AGREEMENTClass Action Settlement Agreement • June 30th, 2016 • California
Contract Type FiledJune 30th, 2016 JurisdictionThis Class Action Settlement Agreement (hereinafter the “Settlement Agreement” or “Agreement”) is made by Plaintiffs Alicia Sumerlin, Denice Sealy, Era Alta, Denise Schwartz, Nicole Crawford, Cordaro Sadder, John Wills, and Derek Brayton (collectively “Named Plaintiffs”) on behalf of themselves and all others similarly situated (including the Settlement Class as defined below) (collectively “Plaintiffs”), and Defendant Maplebear, Inc. d/b/a Instacart (“Instacart” or “Defendant”). Plaintiffs and Defendant will, at times, be referred to collectively herein as “the Parties.” This Settlement Agreement is intended to fully and finally compromise, resolve, discharge and settle all claims brought against Instacart in Sumerlin et al. v. Maplebear, Inc. d/b/a Instacart, Case No. BC603030 (Superior Court for the County of Los Angeles), including as amended pursuant to this Agreement (the “Litigation”), and all claims based on or reasonably related thereto, to the fullest extent reflected herein,