Joint Stipulation and Settlement Agreement Sample Contracts

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • October 19th, 2022 • California

Subject to final approval by the Court, this Joint Stipulation and Settlement Agreement (the “Agreement”) is between Plaintiff Shelby Lowry (“Plaintiff”) on behalf of himself and others similarly situated and other allegedly aggrieved employees and Defendant Woodstock’s Pizza, Inc. (“Defendant”). Plaintiff and Defendant collectively are referred to in this Agreement as the “Parties.”

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JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • March 18th, 2023 • California

Subject to final approval by the Court, this Joint Stipulation and Settlement Agreement is between Plaintiff Jesus Aldana (“Plaintiff”) on behalf of himself, others similarly situated, and other aggrieved employees and Defendant Lyrical Foods, Inc. d/b/a Kite Hill Co. (“Defendant”). Plaintiff and Defendant are collectively referred to herein as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT‌
Joint Stipulation and Settlement Agreement • December 8th, 2022 • California

Subject to Final Approval by the Court, this Settlement Agreement is between Plaintiff Regina Marquez (“Plaintiff”), on behalf of the Class (as defined below), and Defendant Southwire Company, LLC (“Defendant”). Plaintiff and Defendant collectively are referred to in this Agreement as the “Parties.”

FOR THE EASTERN DISTRICT OF CALIFORNIA
Joint Stipulation and Settlement Agreement • September 26th, 2022
JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • August 1st, 2023

This Agreement is made and entered into by and among Plaintiffs and Defendant and is intended by the Parties to fully, finally, and forever resolve, discharge, and settle the Action with respect to the Class Policies and Released Claims with prejudice upon and subject to the terms and conditions hereof.

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • April 26th, 2023 • California

Subject to final approval by the Court, this settlement agreement is made between Plaintiff April Wright (hereinafter “Plaintiff”) on behalf of herself and the Class and Defendants Golden Gate Urgent Care, Inc., Kurt Kunzel, and Mary Jane Connell (hereinafter “Defendants”) (collectively Plaintiff and Defendants are referred to in this Agreement as the “Parties”). This agreement is intended to settle the case entitled April Wright v. Golden Gate Urgent Care, Inc., et al. (Alameda County Superior Court, Case No. RG21092752) (“the Complaint” or “Action”).

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • July 7th, 2022 • California

Subject to final approval by the Court, this Joint Stipulation and Settlement Agreement is entered into between Plaintiff PEDRO RAMOS (“Plaintiff”) on behalf of himself, others similarly situated, and other aggrieved employees and GEORG FISCHER HARVEL LLC, GEORG FISCHER CORPORATION (erroneously sued as GEORG FISCHER INC.), GEORG FISCHER, LLC, GEORG FISCHER CENTRAL PLASTICS

AMENDED JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • September 9th, 2021 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiff Brendan Krick (“Plaintiff”), on behalf of the Class (as defined below) and Defendant SAG-AFTRA Federal Credit Union (“Defendant”). Plaintiff and Defendant collectively are referred to in this Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT‌
Joint Stipulation and Settlement Agreement • November 3rd, 2021 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiff Melinda James (“Plaintiff”) on behalf of herself and others similarly situated and other aggrieved employees and Defendants Coolsys Commercial & Industrial Solutions, Inc., formerly known as Source Refrigeration & HVAC, Inc. and Coolsys, Inc. (“Defendants”). Plaintiff and Defendants collectively are referred to in this Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • February 2nd, 2022 • California

Subject to final approval by the Court, this Joint Stipulation and Settlement Agreement is between Plaintiffs Aharon Spry and Christopher Carrillo (“Plaintiffs,” “Plaintiff Spry,” and “Plaintiff Carrillo”) on behalf of themselves, others similarly situated, and other aggrieved employees and Defendants Prime Lube, Inc. and Blue Sky Golden State, LLC (“Defendants,” “Defendant Prime Lube,” and “Defendant Blue Sky”). Plaintiffs and Defendants are collectively referred to herein as the “Parties.”

FIRST AMENDMENT TO JOINT STIPULATION AND SETTLEMENT AGREEMENT EXECUTED ON AUGUST 31, 2022
Joint Stipulation and Settlement Agreement • August 30th, 2023

EXECUTED ON AUGUST 31, 2022 (the “Amendment”), is made by and between Plaintiff Hannah Williams (“Plaintiff”), on behalf of herself, others similarly situated, and other aggrieved employees and Defendant Cedar Creek Inn SJC, Inc. (“Defendant”) (collectively, the “Parties”) who agree as follows:

FIRST AMENDED JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • October 12th, 2022 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiff Cynthia Dela Vega (“Plaintiff”), on behalf of herself, other members of the general public similarly situated, and other aggrieved employees, and Defendants Valerio’s Tropical Bakeshop I, Inc., Valerio’s Tropical Bakeshop II, Inc., Valerio’s Tropical Bakeshop III, Inc., Valerio’s Tropical Bakeshop V, Inc., Valerio’s Tropical Bakeshop VI, Inc., Valerio’s Tropical Bakeshop VII, Inc., Valerio’s Tropical Bakeshop X, Inc., Valerio’s Tropical Bakeshop XI, Inc., and Valerio’s Tropical Bakeshop XII, Inc. (“Defendants”). Plaintiff and Defendants are collectively referred to in this Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • May 8th, 2023 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiffs Moises Nava, Devin Vester, and Evan Harding (“Plaintiffs”), on behalf of the Class (as defined below) and Defendant Countywide Mechanical Systems, Inc. (“Defendant”) (Plaintiffs and Defendant are collectively are referred to as the “Parties.”)

AMENDED JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • December 6th, 2021 • California

Subject to final approval by the Court, this Settlement Agreement is entered into between Plaintiffs Joshua Mendoza, Randy Williams, and Omar Rivas (“Plaintiffs”), and Defendant Savage Services Corporation (“Defendant” or “Savage Services”). Plaintiffs and Defendant collectively are referred to in this Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • November 20th, 2022 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiffs Daria Regester and Heather Salas-Keen (“Plaintiffs,” “Plaintiff Regester,” and “Plaintiff Salas-Keen”) on behalf of themselves and others similarly situated and other aggrieved employees and Defendant The Jackson Laboratory d/b/a The Jackson Laboratory, West (“Defendant”). Plaintiffs and Defendant collectively are referred to in this Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • December 3rd, 2022 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiffs Steven Hammer and Michael Holdiman (“Plaintiffs”), on behalf of the Class (as defined below) and Defendant Daylight Foods, Inc. (“Defendant”). Plaintiffs and Defendant collectively are referred to in this Agreement as the “Parties.”

SECOND AMENDED JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • June 14th, 2023 • California

Subject to final approval by the Court, this Settlement Agreement is between Jennifer Wise (“Plaintiff”), and Defendants Springs Charter Schools, Inc., River Springs Charter School, Inc., Empire Springs Charter School, Inc., Harbor Springs Charter School, Inc., Citrus Springs Charter School, Inc., Vista Springs Charter School, Inc., and Pacific Springs Charter School, Inc. (collectively “Defendants”). Plaintiff and Defendants collectively are referred to in this Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • February 21st, 2022 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiffs Nguyen Ngo and Chelsea Skolnick (“Plaintiffs”), on behalf of the Class (as defined below) and Defendant MedImpact Healthcare Systems, Inc. (“Defendant”) (Plaintiffs and Defendant are collectively are referred to as the “Parties.”)

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • November 22nd, 2022 • California

Subject to final approval by the Court, this settlement agreement is made between Plaintiffs Alicia Juarez and Karla Martinez Flores (hereinafter “Plaintiffs”), on behalf of themselves and the Class, and Defendants Florexpo, LLC and Kendal Floral Supply, LLC (hereinafter “Defendants”) (collectively Plaintiffs and Defendants are referred to in this Agreement as the “Parties”). This agreement is intended to settle the matters entitled Alicia Juarez v. Florexpo, LLC; Kendal Floral Supply, LLC, San Diego Superior Court Case No. 37-2020- 00016123-CU-OE-CTL, (the “Class Action”) and Alicia Juarez v. Florexpo, LLC; Kendal Floral Supply, LLC, San Diego Superior Court Case No. 37-2020-00015644-CU-OE-CTL, (the “PAGA Action”) (collectively “the Lawsuits”)

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • December 17th, 2019 • California

This Joint Stipulation and Settlement Agreement is made and entered between defendants Hort Tech LLC, Hort Tech, Inc. (collectively referred to here as “Hort Tech”)

MODIFICATION TO JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • February 16th, 2021

Pursuant to Section III, Paragraph 14.g of the Joint Stipulation and Settlement Agreement executed by the Parties on or about September 17, 2020 (“Settlement Agreement”), the Parties, through their counsel, commemorate their agreement to modify the Settlement Agreement to allow for the appointment of the Legal Aid Foundation of Los Angeles (“LAFLA”) as the cy pres recipient for the residual of the Settlement in this Litigation. All references to Bet Tzedek in the Settlement Agreement and its Exhibits shall be replaced with LAFLA. Accordingly, the Settlement Agreement and its Exhibits are modified as follows:

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • October 2nd, 2021 • California

Subject to final approval by the Court, this Settlement Agreement (“Agreement”) is between Named Plaintiffs Lanzell Smith and Rande McCormick (“Named Plaintiff(s)” or “Class Representatives”) individually and on behalf of the putative class of other allegedly similarly situated individuals (the “Class” as defined below) (collectively “Plaintiffs”) and Defendant American Campus Communities Services, Inc. (“Defendant”). Plaintiffs and Defendant collectively are referred to in this Agreement as the “Parties.”

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JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • April 5th, 2023 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiff Bryna Schaeffer (“Plaintiff”), on behalf of the Class (as defined below) and Defendant Security Systems Management Inc. (“Defendant”). Plaintiff and Defendant collectively are referred to in this Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • March 31st, 2021 • California

Subject to final approval by the Court, this settlement agreement is made between Plaintiff David Baird (hereinafter “Plaintiff Baird”) on behalf of himself and the Class and Defendant Safe Haven Security Services, Inc. (hereinafter “Defendant” or “Safe Haven”) (collectively Plaintiff and Defendant are referred to in this Agreement as the “Parties”). This agreement is intended to settle the case entitled David Baird v. Safe Haven Security Services, Inc. (San Bernardino County Superior Court, Case No. CIVDS1924470).

AMENDED JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • November 2nd, 2022 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiff Serena Jones (“Plaintiff”), on behalf of the Class (as defined below) and Defendant Amada Weld Tech, Inc. (“Defendant”). Plaintiff and Defendant collectively are referred to in this Settlement Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • October 11th, 2022 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiff Jacob Blea (“Plaintiff”), on behalf of the Class (as defined below) and Defendants Pacific Groservice Inc. and Pittsburg Wholesale Grocers, Inc. d/b/a Pitco Foods (“Defendant”). Plaintiff and Defendant collectively are referred to in this Agreement as the “Parties.”

AMENDED JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • April 6th, 2023 • California

Subject to final approval by the Court, this Joint Stipulation and Settlement Agreement is between Plaintiff Jocelyn Trigueros (“Plaintiff”) on behalf of herself, others similarly situated, and in her capacity as a representative of the State of California, on behalf of other aggrieved employees and Defendant Stanford Federal Credit Union (“Defendant”). Plaintiff and Defendant are collectively referred to herein as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • May 12th, 2021 • California

Subject to final approval by the Court, this settlement agreement is made between Plaintiff Randolph Fitch (hereinafter “Plaintiff”) on behalf of himself and the Class and Defendants Shaw Industries, Inc. and Shaw Industries Group, Inc. (hereinafter “Defendants” or “Shaw”) (collectively, Plaintiff and Defendants are referred to in this Agreement as the “Parties”). This agreement is intended to settle the case entitled Randolph Fitch v. Shaw Industries, Inc. and Shaw Industries Group, Inc. (San Bernardino County Superior Court, Case No. CIVSB2024674).

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • January 23rd, 2023 • California

Subject to final approval by the Court, this Joint Stipulation and Settlement Agreement is between Spencer Norman (“Plaintiff”) on behalf of himself and others similarly situated and Defendants B&H Global Marketing, LLC and Golden State Crushing (“Defendants”). Plaintiff and Defendants are collectively referred to herein as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • May 4th, 2018 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiff Leonardo Motta (“Plaintiff”) and Defendants Roadrunner Transportation Services, Inc. and Central Cal Transportation, LLC (“Defendants”). Plaintiff and Defendants collectively are referred to in this Agreement as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • December 21st, 2022 • California

Subject to final approval by the Court, this Joint Stipulation and Settlement Agreement is between Plaintiffs Anthony Penca and Christopher Davidson (“Plaintiffs”) on behalf of themselves, others similarly situated, and other aggrieved employees and Defendant Sierra Nevada Brewing Co. (“Defendant”). Plaintiffs and Defendant are collectively referred to herein as the “Parties.”

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • March 23rd, 2023 • New York

This Joint Stipulation and Settlement Agreement (“Agreement” or “Settlement Agreement”) is made and entered into by and among the Named Plaintiffs Yangel Aguilera, Clint Millien, Jonas Jonavan Acevedo, and Adonis Duran (“Named Plaintiffs”), individually and on behalf of the Settlement Class defined below, and Defendant Uber Technologies, Inc. d/b/a Uber Eats (“Defendant” or “Uber,” together with Plaintiffs, the “Parties”).

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • July 1st, 2022 • California

Subject to final approval by the Court, this Settlement Agreement is between Plaintiffs Zaid Hassan and Rebecca Cummins (collectively, “Plaintiffs” or respectively, “Plaintiff Hassan” and “Plaintiff Cummins”), on behalf of the Class (as defined below) and Defendant WestPac Labs, Inc. (“Defendant”).

JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • June 1st, 2020 • California

Subject to final approval by the Court, this settlement agreement is made between Plaintiffs Carl Curtis and Arthur Williams (hereinafter “Plaintiffs”) on behalf of himself and the class and Irwin Industries, Inc. (hereinafter “Defendant” or “Irwin”) (collectively Plaintiffs and Defendant are referred to in this Agreement as the “Parties” or singularly as “Party”). This agreement is intended to settle the case entitled Curtis v. Irwin Industries, Inc., Case No. 2:15-cv-02480 pending in the United States District Court, Central District of California.

AMENDED JOINT STIPULATION AND SETTLEMENT AGREEMENT
Joint Stipulation and Settlement Agreement • March 8th, 2022 • California

Subject to final approval by the Court, this settlement agreement is made between Plaintiff Kendron Fryer (hereinafter “Plaintiff”) on behalf of himself and the Class and Defendant Transforce, Inc. (hereinafter “Defendant” or “Transforce”) (collectively Plaintiff and Defendant are referred to in this Agreement as the “Parties”). This agreement is intended to settle the cases entitled Kenbron Fryer v. Transforce, Inc. (Alameda County Superior Court, Case No. RG20071048) and Kenbron Fryer v. Transforce, Inc. (Alameda County Superior Court, Case No. HG20075197) (collectively, “the Complaints” or “Action”).

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