Proposed Settlement Agreement and Release Sample Contracts

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY NEWARK DIVISION
Proposed Settlement Agreement and Release • November 19th, 2021
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PROPOSED SETTLEMENT AGREEMENT AND RELEASE
Proposed Settlement Agreement and Release • April 9th, 2018

Plaintiffs Keith Cole, Jackie Brannum, Richard Elvin King, Fred Wallace, Michael Denton, and Marvin Ray Yates, individually and on behalf of those similar situated, and Defendants Bryan Collier in his official capacity, Robert Herrera in his official capacity, and the Texas Department of Criminal Justice (TDCJ), enter into this Settlement Agreement and Release (Settlement Agreement”), subject to the approval of the Court. The Parties, in consideration of the mutual promises, agreements, and covenants contained herein, the sufficiency and receipt of which are hereby acknowledged, stipulate and agree as follows:

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY NEWARK DIVISION
Proposed Settlement Agreement and Release • November 19th, 2021
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