SETTLEMENT AGREEMENT AND RELEASE AS TO ATTORNEYS’ FEES, EXPENSES, AND TAXABLE COSTSSettlement Agreement • February 16th, 2022
Contract Type FiledFebruary 16th, 2022This Agreement relates to Civil Case No. 4:15-cv-250-DCB (D. Ariz.) (“the Litigation”) by Jane Doe #1, Jane Doe #2, and Norlan Flores, on behalf themselves and the class of all individuals who are now or in the future will be detained in a CBP facility within the Border Patrol’s Tucson Sector (collectively “Plaintiffs”), against Defendants Alejandro Mayorkas, Secretary, U.S. Department of Homeland Security; Chris Magnus, Commissioner, U.S. Customs and Border Protection; Raul L. Ortiz, Chief, U.S. Border Patrol; and John Modlin, Chief Patrol Agent – Tucson Sector in their official capacities (“Defendants”).1 Plaintiffs and Defendants (“the Parties”) hereby AGREE, through their respective attorneys, subject to the approval of the Court pursuant to Rule 23(h) of the Federal Rules of Civil Procedure, that the settled claims for fees, expenses, and taxable costs incurred in connection with the Litigation, shall be compromised, settled, forever released, barred, and dismissed with prejudice,