Class Settlement Agreement Sample Contracts

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Class Settlement Agreement • April 8th, 1999 • BGLS Inc • Cigarettes
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CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • July 12th, 2022 • Massachusetts

This Class Settlement Agreement is made by and between the Class Representatives, individually and on behalf of the Settlement Class, Defendants, and the Governor’s Office for the Commonwealth of Massachusetts on behalf of the Commonwealth of Massachusetts.1 The Class Representatives, the Settlement Class, Defendants, and the Commonwealth of Massachusetts are collectively referred to as the “Parties.” If appointed by the Court, Class Counsel and the Claims Administrator by signing this Agreement also undertake certain obligations required of them by the Agreement and enjoy certain rights afforded them by this Agreement.

Contract
Class Settlement Agreement • July 2nd, 2021 • Missouri

This Class Settlement Agreement (“Agreement”) is entered into by and between: (i) Plaintiff Michael Dinges (“Plaintiff” or “Settlement Class Representative”), for himself and on behalf of the Settlement Class; and (ii) Defendant Stanley Black & Decker, Inc. (All capitalized terms used herein are as defined in Section 2.)

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • January 14th, 2021

This Class Settlement Agreement (“Agreement”) is entered into on August , 2019, by and between Megan Schmitt, Stephanie Miller-Brun, Deana Reilly, Kristen Bowers, Brenna Kelly-Starkebaum, Aschley Willey, Mekenzie Davis, Michelle Ellis, Jan Taylor, Nevina Saitta, Meagan Nelson and Casey Ratliff (collectively “Plaintiffs”), on behalf of themselves and the members of the Settlement Class, on the one hand, and Defendant Younique LLC (“Younique”) (collectively, Plaintiffs and Younique are the “Parties”). The Parties intend for this Agreement to fully, finally, and forever resolve, discharge, and settle all released rights and claims, subject to the terms and conditions set forth herein.

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • May 11th, 2020 • Missouri

This class settlement agreement (“Settlement Agreement”) is entered into by and between Costco Wholesale Corporation (“Costco”) and Scott Pearlstone (“Plaintiff”), both individually and on behalf of the Settlement Class Members.

IN RE MAUI WILDFIRES CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • November 5th, 2024 • Hawaiian Electric Co Inc • Electric services

This CLASS SETTLEMENT AGREEMENT, dated as of November 1, 2024 (the “Settlement Date”), is made and entered into by and among Class Counsel, Class Representatives, and Defendants, who are parties to the Consolidated Complaint arising out of the Maui windstorm and fires of August 2023, including the fires in Lahaina, Kula, and Olinda (“Maui Fires”). This Class Settlement Agreement, together with the Individual Settlement Agreement that Defendants are entering into simultaneously, is intended by the Parties to fully and finally compromise, settle, resolve, discharge, release, and dismiss with prejudice on a comprehensive, global basis all Released Claims against the Releasees, as set forth below, under the terms set forth herein, subject to review and approval by the Approving Court and satisfaction of all other Conditions set forth below.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Class Settlement Agreement • May 11th, 2022 • California

This Class Settlement Agreement (“Settlement Agreement”) is entered into by and between Plaintiffs Ian Vianu, Elizabeth Blum, and Dominic Gutierrez (together, “Plaintiffs”) on behalf of themselves and the Settlement Class (as defined below), and Defendant AT&T Mobility LLC (“AT&T”) (collectively, the “Parties”). This Settlement Agreement is conditioned upon and subject to approval of the Court as required by Rule 23 of the Federal Rules of Civil Procedure. Settlement Class Counsel (as defined below) and the Parties stipulate and agree that, in consideration of the promises and covenants set forth in this Settlement Agreement and upon the Effective Date (as defined below), this Action (as defined below) and all Released Claims (as defined below) shall be finally and fully settled, compromised, and released, on the following terms and conditions:

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • November 4th, 2024

This CLASS SETTLEMENT AGREEMENT, dated as of November 1, 2024 (the “Settlement Date”), is made and entered into by and among Class Counsel, Class Representatives, and Defendants, who are parties to the Consolidated Complaint arising out of the Maui windstorm and fires of August 2023, including the fires in Lahaina, Kula, and Olinda (“Maui Fires”). This Class Settlement Agreement, together with the Individual Settlement Agreement that Defendants are entering into simultaneously, is intended by the Parties to fully and finally compromise, settle, resolve, discharge, release, and dismiss with prejudice on a comprehensive, global basis all Released Claims against the Releasees, as set forth below, under the terms set forth herein, subject to review and approval by the Approving Court and satisfaction of all other Conditions set forth below.

Contract
Class Settlement Agreement • April 20th, 2023 • Missouri

This Class Settlement Agreement (“Agreement”) is entered into by and between: (i) Plaintiff Jeffrey Tuter (“Plaintiff” or “Settlement Class Representative”), for himself and on behalf of the Settlement Class; and (ii) Defendant Freud America, Inc. (All capitalized terms used herein are as defined in Section 2.)

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • April 27th, 2021 • Michigan

This Class Settlement Agreement is entered into as of the 22nd day of April, 2021, by and among Plaintiffs, on behalf of themselves and the Class Members, and Defendants.

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • April 13th, 2004 • California

This is an agreement to settle portions of a class action lawsuit and a representative group action brought under California Business and Professions Code section 17200 against Apollo Group, Inc., an Arizona Corporation, and University of Phoenix, Inc., an Arizona Corporation.

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • February 22nd, 2024 • Georgia

This Class Settlement Agreement (“Agreement”) is made and entered into as of February 2, 2024, by and among the following parties (the “Parties”):

Contract
Class Settlement Agreement • December 5th, 2023 • Missouri

This Class Settlement Agreement (“Agreement”) is entered into by and between: (i) Plaintiff Melvin Lampton (“Plaintiff” or “Settlement Class Representative”), for himself and on behalf of the Settlement Class; and (ii) Saint-Gobain Abrasives, Inc. (All capitalized terms used herein are as defined in Section 2.)

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • February 22nd, 2024

This Class Settlement Agreement (“Settlement Agreement”) is made and entered into by and between Plaintiff Nicole Yount (“Plaintiff” or “Class Representative”), individually and on behalf of the Settlement Class (as defined in Paragraph 2, below), on the one hand, and Defendants Diamond Parking, Inc. and Diamond Parking Services, LLC (collectively, “Defendants”), on the other hand, in Nicole Yount v. Diamond Parking, Inc. et al., King County Superior Court Case No. 23-2-19309-1 SEA (the “Action”). This Settlement Agreement is subject to the terms and conditions hereof and the approval of the Court. For purposes of this Settlement Agreement, Plaintiff and Defendants are referred to individually as a “Party” and collectively as the “Parties.”

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • March 25th, 2013

This Class Settlement Agreement is entered into by and between Plaintiff Verie Poole, on behalf of herself and all those in the Settlement Class as defined herein, and The Eichholz Law Firm, P.C. and Pacific Legal Funding, LLC, the named Defendants in the above-captioned case (the “Action”).

UNITED STATES DISTRICT COURT
Class Settlement Agreement • December 10th, 2018
CLASS SETTLEMENT AGREEMENT BETWEEN D&G, INC. ON BEHALF OF THE CHAMPAIGN DC NON- ARBITRATION CLASS AND SUPERVALU INC.
Class Settlement Agreement • August 22nd, 2017 • Minnesota

This Class Settlement Agreement (“Settlement Agreement” or “Agreement”) is made and entered into as of this 24th day of July, 2017, by and between the Settling Parties: Supervalu Inc. (“Supervalu”) and Plaintiff D&G, Inc., on behalf of the Champaign DC Non-Arbitration Class (collectively the “Settlement Class”), as defined herein and in the Court’s Class Certification Order in In re Wholesale Grocery Products Antitrust Litigation, 09-md-2090 (D. Minn. Sept. 7, 2016), ECF No. 651, subject to the approval of the Court (the “Settlement”). The Settling Parties intend for the Class Settlement Agreement to fully, finally, and forever resolve, discharge, and settle all released rights and claims, subject to the terms and conditions set forth in this Agreement.

APPENDIX A
Class Settlement Agreement • September 18th, 2018
CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • December 1st, 2020 • Missouri
CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • October 16th, 2020

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CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • December 15th, 2020 • Kansas

This Class Settlement Agreement and Release, and its attached exhibits (“Settlement Agreement” or “Agreement”) is entered into by and between Class Representative Plaintiffs listed in paragraph 2 below (“Class Representatives” or “Plaintiffs”), entered into as of the 15th day of December, 2020, individually and on behalf of Participating Settlement Class Members (together “Plaintiffs”), and Hill’s Pet Nutrition, Inc., Hill’s Pet Nutrition Sales, Inc. (collectively “Hill’s”) and Colgate-Palmolive Co. (“Colgate”) (collectively with Hill’s, the “Defendants,” and collectively with Plaintiffs, the “Parties”). This Settlement Agreement is intended by the Parties to resolve, discharge, and settle the Released Claims (as defined herein), upon and subject to the terms and conditions of this Agreement, conditioned upon Court approval of the terms and conditions hereof.

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SUPERIOR COURT OF CALIFORNIA COUNTY OF HUMBOLDT VINNIE LAVENDER by and through her Conservator, WANDA BAKER; WALTER SIMON; JACQUE LYN VILCHINSKY, Plaintiffs, vs. SKILLED HEALTHCARE GROUP, INC., et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) Case No....
Class Settlement Agreement • September 8th, 2010 • Skilled Healthcare Group, Inc. • Services-skilled nursing care facilities • California

This Class Settlement Agreement and Release (the “Settlement Agreement”) is entered into as of September 7, 2010 (the “Settlement Date”), subject to the approval of the Court, by and among: (i) Plaintiffs Vinnie Lavender by and through her Conservator; Wanda Baker; Walter Simon; and Jacquelyn Vilchinsky (collectively, the “Named Plaintiffs,” and, together with the Class (as defined below), the “Plaintiffs”); and (ii) Defendants Skilled Healthcare Group, Inc. (“SKH”); Skilled Healthcare, LLC; Granada Healthcare and Rehabilitation Center, LLC; Eureka Healthcare and Rehabilitation Center, LLC; Pacific Healthcare and Rehabilitation Center, LLC; Seaview Healthcare and Rehabilitation Center, LLC; St. Luke Healthcare and Rehabilitation Center, LLC; Bay Crest Care Center, LLC; Brier Oak on Sunset, LLC; The Earlwood, LLC; Royalwood Care Center, LLC; Sycamore Park Care Center, LLC; Villa Maria Healthcare Center, LLC; Valley

DEREK VOLKMAN, on behalf of himself and all others similarly situated,Plaintiff, vs. Case No. 1:18-cv-00091-WCG ENHANCED RECOVERY COMPANY,LLC, a Delaware Limited Liability Company, d/b/a ERC,Defendants. CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • September 23rd, 2020

This Class Settlement Agreement dated as of September 23, 2020, (“Agreement”), is made and entered into by and among the following Parties: (i) Plaintiff, Derek Volkman, individually and on behalf of certified Class Members, by and through Class Counsel; and (ii) Defendant, Enhanced Recovery Company, LLC d/b/a ERC (“ERC”), by and through its counsel of record in this Litigation.1 Plaintiff and ERC are collectively referred to as the “Parties.” The Parties intend for this Agreement to fully, finally, and forever resolve, discharge, and settle all released rights and claims, as set forth below, subject to the terms and conditions set forth herein.

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • February 15th, 2019 • New York

This Settlement Agreement is entered into by Plaintiffs Linda Taylor Gay, Marianne Norelli, Rocco Commisso and Galo Uribe (“Representative Plaintiffs” or “Plaintiffs”), acting individually and on behalf of the Settlement Class defined below, and Defendants Midland Funding, LLC and Midland Credit Management, Inc. (collectively, “Midland” or “Defendants”). This Settlement Agreement is subject to preliminary and final approval by the Court pursuant to Rule 23 of the Federal Rules of Civil Procedure.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Class Settlement Agreement • April 7th, 2021 • California

This Class Settlement Agreement (“Settlement Agreement”) is entered into by and between Plaintiffs Marcus A. Roberts, Kenneth A. Chewey, and Ashley M. Chewey (together, “Plaintiffs”) on behalf of themselves and the Settlement Class (as defined below), and Defendant AT&T Mobility LLC (“AT&T”) (collectively, the “Parties”). This Settlement Agreement is conditioned upon and subject to approval of the Court as required by Rule 23 of the Federal Rules of Civil Procedure. Settlement Class Counsel (as defined below) and the Parties hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Settlement Agreement and upon the Effective Date (as defined below), this Action (as defined below) and all Released Claims (as defined below) shall be finally and fully settled, compromised, and released, on the following terms and conditions:

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • April 25th, 2022 • Oregon

The parties to this class settlement agreement (“Agreement”) are Charlotte Hasson, Kathleen Martinez, Mark Frazier, Cathy Gorton, and Ovidiu Sferle (collectively, “the Class Representatives”), Multnomah County (“the County”), and the class as defined below. The effective date of this Agreement is April 28, 2022 (“Effective Date”).

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • January 12th, 2022 • Illinois
CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • July 2nd, 2018

This Class Settlement Agreement dated as of June 12, 2018, (“Agreement”), is made and entered into by and among the following Parties, as those terms are defined herein: (i) Plaintiff, Tamra Foerster, on behalf of herself and each of the Settlement Class members, by and through Class Counsel; and (ii) the Defendant, FirstCollect, Inc., by and through its counsel of record in this Action. This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle all released rights and claims, as set forth below, subject to the terms and conditions set forth herein.

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • December 19th, 2013 • New York

Subject to the preliminary and final approval of the Court, and as further set forth below, this definitive Class Settlement Agreement (this “Class Settlement Agreement”) is made as of the 19th day of December, 2013, by and between the Class Plaintiffs (as defined below), individually and as representatives of the Settlement Class (as defined below), Class Counsel (as defined below), and the Defendants (as defined below).

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • January 21st, 2021

This Class Settlement Agreement is entered into this 27th day of February, 2019, by and between Plaintiff Tony Luib (“Plaintiff”), on behalf of himself and each of the Settlement Class Members (defined below), on the one hand, and Defendant Henkel Consumer Goods Inc. (“Defendant”) (Defendant together with Henkel Corporation and Henkel U.S. Operations Corporation, “Henkel”), on the other hand (Plaintiff and Henkel are each a “Party” and collectively, the “Parties”).

CLASS SETTLEMENT AGREEMENT‌
Class Settlement Agreement • August 12th, 2021

This class settlement agreement (“Agreement”) is made and entered into as of the date the last party signs the Agreement. This Agreement is between plaintiffs Briana Rivera and Rosalio Trujillo Rivera (“Plaintiffs”), on their own behalf and on behalf of a class (as defined below) (“Class”); and (b) defendants Coco Properties JL, LLC, and Jeffery Lee ("Defendants"). Each Plaintiff and Defendant is referred to individually as a “Party,” and collectively Plaintiffs and Defendants are referred to as the “Parties” to this Agreement.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Class Settlement Agreement • March 25th, 2021 • California

This Amended Class Settlement Agreement (“Settlement Agreement”) is entered into by and between Plaintiffs Marcus A. Roberts, Kenneth A. Chewey, and Ashley M. Chewey (together, “Plaintiffs”) on behalf of themselves and the Settlement Class (as defined below), and Defendant AT&T Mobility LLC (“AT&T”) (collectively, the “Parties”). This Settlement Agreement is conditioned upon and subject to approval of the Court as required by Rule 23 of the Federal Rules of Civil Procedure. Settlement Class Counsel (as defined below) and the Parties hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Settlement Agreement and upon the Effective Date (as defined below), this Action (as defined below) and all Released Claims (as defined below) shall be finally and fully settled, compromised, and released, on the following terms and conditions:

CLASS SETTLEMENT AGREEMENT
Class Settlement Agreement • July 11th, 2024

This Class Settlement Agreement (“Settlement Agreement”) is made and entered into by and between Plaintiff Jacob Atkinson (“Plaintiff”), both individually and on behalf of the proposed Settlement Class (as defined below), on the one hand, and Defendants AMF Bowling Centers, Inc. d/b/a AMF Bowlero and Lucky Strike Lanes, Bowlero Broadway Seattle, LLC d/b/a Garage, Bowlero Tukwila, LLC d/b/a Bowlero South Seattle, Bowlero Tacoma, LLC d/b/a Paradise Lanes, Bowlero Sports and Entertainment Holdings, LLC d/b/a PBA, Leiserv, LLC d/b/a Bowlero Lynnwood, Henry Family Enterprises LLC d/b/a Bowlero Lanes of Lakewood (collectively “Defendants”), on the other hand, to resolve all matters arising out of or relating to the matter of Atkinson v. AMF Bowling Centers, Inc., et al., King County Superior Court Case No. 23-2-19816-6 SEA (the “Action”). This Settlement Agreement is subject to the terms and conditions hereof and the approval of the King County Superior Court (the “Court”). For purposes of t

APPENDIX I
Class Settlement Agreement • September 15th, 2016 • California

This Class Settlement Agreement is entered into as of September 9, 2016, by and between James Wesley Carter (“Plaintiff”), on the one hand, and Defendants Shalhoub Management Company, Inc., Desert Gate Management LLC, DNR Management LLC, DNS2 Management LLC, Shalhoub McDonald’s, Richard and Dale Shalhoub Family Trust, Richard M. Shalhoub (“Defendants” or “Shalhoub Defendants”), on the other.

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