STIPULATION OF AGREEMENT AND SETTLEMENT AND RELEASEStipulation of Agreement and Settlement and Release • July 23rd, 2020 • California
This Stipulation of Agreement and Settlement and Release is entered into by and among the Named Plaintiffs (as defined below), for themselves and on behalf of the Settlement Class, and Defendant Activehours, Inc. d/b/a Earnin (“Earnin” or “Defendant”), subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Defendant and the Named Plaintiffs hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against the Defendant as alleged in the complaint filed in the action titled Perks, et al, v. Activehours, Inc. d/b/a Earnin, Case No. 5:19-cv-05543-BLF (N.D. Cal.) shall be settled and compromised upon the terms and conditions contained herein. The Named Plaintiffs and Defendant are collectively referred to herein as the “Parties.”
STIPULATION OF AGREEMENT AND SETTLEMENT AND RELEASEStipulation of Agreement and Settlement and Release • May 19th, 2023 • California
This Stipulation of Agreement and Settlement and Release is entered into by and among the Named Plaintiff (as defined below), for himself and on behalf of the Settlement Class, and Defendant Dave Inc. (“Dave” or “Defendant”), subject to preliminary and final Court approval as required by California Rule of Court 3.769. As provided herein, Defendant and the Named Plaintiff hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against the Defendant in connection with the Data Breach (defined below) as alleged in the action titled Stoffers v. Dave Inc., Case No. 20STCV35381 (LA Superior Court) shall be settled and compromised upon the terms and conditions contained herein. The Named Plaintiff and Defendant are collectively referred to herein as the “Parties.”
STIPULATION OF AGREEMENT AND SETTLEMENT AND RELEASEStipulation of Agreement and Settlement and Release • July 27th, 2020 • California
This Stipulation of Agreement and Settlement and Release is entered into by and among the Named Plaintiffs (as defined below), for themselves and on behalf of the Settlement Class, and Defendant Activehours, Inc. d/b/a Earnin (“Earnin” or “Defendant”), subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Defendant and the Named Plaintiffs hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against the Defendant as alleged in the complaint filed in the action titled Perks, et al, v. Activehours, Inc. d/b/a Earnin, Case No. 5:19-cv-05543-BLF (N.D. Cal.) shall be settled and compromised upon the terms and conditions contained herein. The Named Plaintiffs and Defendant are collectively referred to herein as the “Parties.”
EXHIBIT AStipulation of Agreement and Settlement and Release • February 24th, 2022 • Texas
This Stipulation of Agreement and Settlement and Release is entered into by and among Named Plaintiffs, for themselves and on behalf of the Settlement Class, and Defendants Insurance Technologies Corp. and Zywave, Inc. (“ITC” or “Defendants”), subject to preliminary and final Court approval as required by Federal Rule of Civil Procedure 23(e). As provided herein, Defendants and Named Plaintiffs hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against Defendants in connection with the Data Breach (defined below) as alleged in the action titled Heath, et al. v. Insurance Technologies Corp. and Zywave, Inc., Case No. 3:21- cv-01444-N (N.D. Tex.) shall be settled and compromised upon the terms and conditions contained herein. Named Plaintiffs and Defendants are collectively referred to herein as the “Parties.”
