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the * * * Plaintiffs * * * hereby release and discharge
PayLess * * * from all actions, claims, or demands for
damages, liabilities, costs, or expenses, which the
Plaintiffs * * * have against PayLess on account of, or in
any way arising out of the claims that were asserted or that
could have been asserted in the Lawsuit by the Plaintiffs *
* * including, but not limited to, claims for personal
injuries, intentional infliction of emotional distress,
negligent infliction of emotional distress, and from all
known claims, whether based on tort, statute or contract,
which are based in whole or in part, or arise out of, or in
any way relate to: (1) the Lawsuit; and (2) anything done or
allegedly done by PayLess arising out of, or in conjunction
with or relating to, the employment of any and/or all
Plaintiffs * * * by PayLess.
The Settlement Agreement additionally included section 8,
entitled Liability Denial and Basis For Settlement, which
provided:
PayLess denies any liability on its part and enters
into this agreement solely to avoid litigation and to buy
its peace. All Settlement Proceeds are paid to Plaintiffs
on account of personal injuries. This Settlement Agreement
and the releases contained herein settle and resolve all
claims which have to this point been contested and denied by
the parties, as well as all other claims released by
paragraphs 3 and 4 of this Settlement Agreement. None of
the provisions of this Settlement Agreement and nothing
contained in this Settlement Agreement shall be construed as
an admission of any liability whatsoever by any party hereto
to any other party hereto.
As a member of the class of former employees of PayLess,
petitioner received the following amounts out of the $5 million
settlement:
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Last modified: May 25, 2011