SETTLEMENT AGREEMENT AND RELEASESettlement Agreement and Release • May 1st, 2023 • California
Contract Type FiledMay 1st, 2023 JurisdictionThis Settlement Agreement and Release (the “Settlement Agreement”), effective as of the date of the last signature below, is made by and between Plaintiff Terry Fabricant (“Plaintiff”), individually and on behalf of the Settlement Class as further defined herein, and Defendant Top Flite Financial, Inc. (“Defendant” or “TF”), subject to Court approval as required by California Rules of Court Rule 3770. As provided herein, the Parties hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Settlement Agreement and upon entry by the Court of a Final Approval Order and Final Judgment, all claims of Plaintiff and the Settlement Class against Defendant asserted in Terry Fabricant, individually and on behalf of all others similarly situated, v. TOP FLITE FINANCIAL, INC., Case No. 20STCV13837, pending before the Superior Court of California County of Los Angeles, shall be fully and finally settled and compromised upon the terms and conditions set forth