CLASS ACTION & PAGA SETTLEMENT AGREEMENTClass Action & Paga Settlement Agreement • October 10th, 2019 • California
Contract Type FiledOctober 10th, 2019 JurisdictionThis Class Action & PAGA Settlement Agreement (hereinafter the “Settlement Agreement” or “Agreement”) is made and entered into by, between, and among Plaintiffs Seth Blackham, Stephen McFadyen, and Monica Garcia (collectively “Named Plaintiffs”), on behalf of themselves and the Settlement Class as defined below, and Defendant Lyft, Inc. (“Defendant” or “Lyft”). Named Plaintiffs and Lyft (collectively, the “Parties”) enter into this Agreement to effect a full and final settlement and dismissal with prejudice of the Released Claims as defined below. This Settlement Agreement is intended to fully and finally compromise, resolve, discharge, and settle the Released Claims, as defined and on the terms set forth below, and to the full extent reflected herein, subject to the approval of the Court.