CLASS ACTION AND PAGA SETTLEMENT AGREEMENT AND CLASS NOTICEClass Action and Paga Settlement Agreement and Class Notice • March 7th, 2023 • California
Contract Type FiledMarch 7th, 2023 JurisdictionThis Class Action and PAGA Settlement Agreement (“Agreement”) is made by and between Plaintiffs Yvette Cosme, Cari Walker, and Flor Alejandra Rodriguez (together “Plaintiffs”) (collectively, “Class Representatives” or “Plaintiffs”), individually and on behalf of all putative class members, putative aggrieved employees, and the State of California, on the one hand, and Defendant Ambitions California, Inc. (“Ambitions”) on the other hand. The Settlement Agreement refers to Plaintiffs and Ambitions collectively as “Parties,” or individually as “Party.” This Settlement Agreement is subject to the terms and conditions set forth below and the Court’s approval. This Settlement Agreement completely resolves the Released Class Claims (as defined herein) and Released PAGA Claims (as defined herein) against the Released Parties (as defined herein).