CLASS ACTION SETTLEMENT AGREEMENTClass Action Settlement Agreement • September 17th, 2020 • California
Contract Type FiledSeptember 17th, 2020 JurisdictionThis Class Action Settlement Agreement (the “Settlement Agreement” or “Agreement”) is entered into by and among plaintiffs Steve Ferrari, Michael Keynejad, Patricia Rubin, John Diaz, Ray Gapasin, and Harold Fethe (collectively, “Class Representatives” or “Named Plaintiffs”), on behalf of themselves and the Settlement Class (defined below) that they represent, Autobahn, Inc. (“Autobahn”), Sonic Automotive, Inc. (“Sonic”) (collectively Autobahn and Sonic are the “Autobahn Defendants”). Mercedes-Benz USA, LLC (“MBUSA”) is a third-party beneficiary of the Release as set forth below for some of the claims being resolved herein. Other claims against MBUSA will continue. The Named Plaintiffs together with the absent class members are referred to herein as the “Plaintiffs.”