SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • February 27th, 2019 • New York
Contract Type FiledFebruary 27th, 2019 JurisdictionThis Settlement Agreement and Release (“Agreement”) is made and entered into this 27th day of February, 2019, by and among (1) Jack Battaglia (“Plaintiff”), on behalf of himself and all others similarly situated, and (2) BRE Select Hotels Corp (“BRE” or “Defendant,” together with Plaintiff, the “Parties”) subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. The Parties hereby agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a Final Order and Judgment after Final Approval and payment of the Settlement Amount, all claims of the Settlement Class against Defendant in the above-captioned action, shall be settled and compromised upon the terms and conditions contained herein. The parties will request that the Court retain jurisdiction with regard to all matters relating to the enforcement of this Settlement.