SETTLEMENT AGREEMENT AND GENERAL RELEASE 

This Settlement Agreement and General Release (this "Settlement Agreement'') is entered 

into by and among STACY A. HJLL, including his heirs, executors, representatives, agents, 

insurers, successors, and assigns (hereinafter referred to as uPlaintiff"), and TASTE RITE, lNC.

d/b/a Taste Rite, PUERTO SECO, INC. d/b/a Rite, LYNDEN GORDON and JENNIFER 

CLARKE, including its predecessors, successors and assigns, parent corporations, subsidiary 

corporations, affiliated corporations, partners, attorneys, insurers and agents, (hereinafter 

collectively referred to as "Defendants"), and (hereinafter Defendants and Plaintiff collectively 

referred to as the "Parties"), for good and valuable consideration, receipt of which is hereby 

acknowledged, and in order to resolve and settle finally, fully and completely all matters or 

disputes that now exist or may exist between them prior to the date of this fully executed 

Settlement Agreement, the Parties enter into this Settlement Agreement and General Release 

this 4th day of September, agreeing as follows: 

l. General Belrue. In consideration for the promises contained in this Settlement

Agreement, the Plaintiff unconditionally releases and discharges Defendants (collectively 

referred to as the "Released Parties") from any and all claims, demands, liabilities, and causes of 

action of any kind or nature, whether known or unknown, or suspected or unsuspected, which 

Plaintiff now owns or holds, or has owned or held against the Released Parties, including, but not 

limited to, any and all claims, demands, liabilities, causes of action, and all incurred attorney's 

fees and costs, that arise out of, or are in any way connected with Plaintiff's employment with, or 

the separation of Plaintiff's employment with the Defendants, or that arise out of or are in any 

way connected with any loss, damage, or injury whatsoever to Plaintiff resulting from any act or 

omission by or on the part of the Released Parties committed prior to the date of this Agreement. 

Included in the claims, demands, liabilities, and causes of action being released and discharged 

by Plaintiff are all claims under: 

• Title VII of the 1964 Civil Rights Act;

• The Civil Rights Act ofl991;

• The Age Discrimination in Employment Act;

• The Older Workers Benefit Protection Act;

• The Equal Pay Act;

• The Fair Labor Standards Act ("FLSA");

• The Plaintiff Retirement Income Security Act{ERISA);

• The Americans with Disabilities Act of l 990;

• The Rehabilitation Act of 1973;

• The Family and Medical Leave Act of 1993; 42 U.S.C. §§ 1981, 1985(3), and 1986;

• The Occupational Safety and Health Act;

• The Florida Civil Rights Act, Chapter 760, Florida Statutes;

• The Florida Private Whistle-blow s Act of! 991;

[ D 1iA ] �-

Av:_ 

, • ...,.,.AQg,,_...,..,.. __ Stacy A. Hilr...,.::,7,:..,....,..-TASIB RITE, INC.�--_ 

__ PUERTO SECO, N,r_,'=.. -P ---:i-_Lynden Gordon.� Jennifer Clarke 

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 1

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 1 of 10
SettlemLnl Agrumenl and General Rekase 

• Workers' ompensation claims,

Any and all other laws, statutes, ordinances, treaties, ruJes or regulations of the United

talcs of America, or any other country, state, county, municipality, or political 

subdivision thereof,. 

• Any claims arising under any other federal, sta

te or local statute or act, ordinance, 

regulation, custom, rule or policy; 

I aims for breach of a contract, implied contract, or quantum meruit, or any cause of 

action or claim for tort damages, negligence or personal injury by, between, or among 

the Parties; and 

I aims under any instruments, agreements, or documents entered into by, between, or 

among the Parties. 

ln consideration for the mutual promises exchanged herein, Plaintiff releases and forever 

discharges Defendants and all Released Parties from any and all claims of any kind that Plaintiff 

had, now has, or hereinafter could, should or may have against Defendants, whether known or 

unknown, by reason of any acts, omissions, events, matters, causes, facts or things occurring or 

existing prior to the date this Settlement Agreement is fully executed and unconditionally 

delivered by the Parties. Upon execution of this Settlement Agreement and Release, Plaintiff 

hereby explicitly waives the right to file suit in any court of competent jurisdiction based on 

anything arising out of her employment with Defendants. The Defendants agree it will not contest 

any application(s) for unemployment compensation benefits submitted by Plaintiff to .Florida's 

Department of Economic Opportunity. 

In further consideration for the promises contained in this Agreement, specifically the 

waiver of all claims arising separately from the FLSA, Defendants unconditionally releases and 

discharges Plaintiff from any and all claims, demands, liabilities, and causes of action of any kind 

or nature, whether known or unknown, or suspected or unsuspected, that it now owns or holds, or 

has owned or held against the Plaintiff, limited to any and all claims, demands, liabilities, causes 

of action, and all incurred attorneys' fees and costs, that arise out of, or are in any way connected 

with Plaintiff's employment with, or the separation of Plaintiff's employment with the Defendant, 

or that arise out of or are in any way connected with any loss, damage, or injury whatsoever to 

Defendants resulting from any act or omission by or on the part of the Plaintiff related to her 

employment with Defendants, prior to the date of this Settlement Agreement. 

This Settlement Agreement shall affect the release of all claims that were, or could have 

been, asserted by and among Plaintiff and Defendants in the lawsuit styled STACY A. HILL v.

JENNIFER 

TASTE RITE, INC. d/b/a Taste Rite, PUERTO SECO INC. dlbla Rite, LYNDEN GORDO. and

CLARKE (collectively the "Defendants") CASE NO.: 0:20-cv-61445-RAR, pending 

before the United States District Court for the Southern District of Florida (hereinafter referred to 

as the "Litigation") as well as any other claim, charge, or allegation of damages of any kind. 

,oaa.,,y[Jl()g7"n'A■•.., .. __ Stacy A. Hil TASTE RITE, INe:'d"' __ 

l.M\!- j � .,/,,, y_ PUERTO SECO, IN . Lynden Gordon. �ennifcr Clarke 

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 2

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 2 of 10
&tt.lemau Agrlllnfflt and General Rdease 

Plaintiff represents that she will promptly dismiss or cause to be dismissed any and all claims of 

any kind against Defendants within 3 days of receipt of payment 

The Parties acknowledge that by executing this Settlement Agreement and General 

Release, the Parties are hereby releasing all claims known and unknown, asserted or unasserted, 

whjch the Defendants has against Plaintiff, and which Plaintiff has against Defendants as of the 

date of execution of this Settlement Agreement and General Release. 

2. Settlement Amoupt apd Attorneys' fees. In consider

a

tion of the mutual

promjses exchanged herein, Defendants shall pay the total sum of 1WEL VE THOUSAND FNE 

HUNDRED DOLLARS AND ZERO CENTS ($12,500.00) (the "Settlement Funds"}, and shall 

be disbursed by Plaintiff's Counsel, Saenz & Anderson, PLLC, and allocated as follows: 

a. Plaintiff shall receive as alleged unpaid wages, liquidated and other

damages, the total amoun

t of Six Thousand Seven Hundred and Sixty Dollars and 00/100 

Cents ($6,760.00), of which Three Thousand Three Hundred Eigh

ty Dollars represent 

unpaid wages ($3,380.00) and Three Thousand Three Hundred Eighty Dollars ($3,380.00) 

represent liquidated damages,within five (5) calendar days of her execution of this 

Settlement Agreement and General Release; and 

b Plaintiff's Counsel, Saenz & Anderson, PLLC, shall receive the total

amount of Five Thousand Seven Hundred Dollars Forty and 00/100 Cents ($5,740.00), of 

which includes Five Thousand One Hundred Dollars and 00/100 Cents ($5,100.00) 

represents attorneys' fees and Six Hundred and Forty Dollars and 00/100 Cents ($640.00) 

represents litigation costs, within five (5) calendar days of Plaintiff's execution of this 

Agreement and General Release. 

The above-referenced Settlement Payment will be paid no later than f

ive (5) calendar days 

from Plaintiff's execution of this Settlement Agreement and General Release'. The total sum 

Settlement Payment (Plain1ifrs portion of the Settlement Payment (as identified in 2(a) and 

Plaintiff's counsel's portion of the Settlement Payment (as identified in 2(b)), in the amount of 

$ I 2, 500, will be paid via two (2) cashier's checks. Plaintiff's counsel will forward to Defendan

ts' 

counsel a completed IRS Form W-9 for Saenz & Anderson, PLLC. 

Plaintiff understands and agrees that she would not receive the Settlement Payment except 

for the fulfillment of the promises contained herein. In the event that Plaintiff claims that the 

Settlement Payment or any portion thereof is untimely, Plaintiff shall notify the Defendants by 

an email sent to Defendants and its lawyers, of untimely payment and shall provide the 

1 Plaintiff's counsel already received all settlement payments due on or about September 8, 2020. 

The Parties are awaiting this Court's approval of the Settlement Agreement and the dismissal with 

prejudice of thjs action so that all settlement moneys can be disbursed to Plaintiff and her counsel. 

IO-Qe-AIIDI __ Stacy A. Hil TASTE RITE

[ hlll l * , INC.�-- /( � 

4. __ PUER

TO SECO, IN ynden Gordon�nrufer Clarke 

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 3

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 3 of 10
Settlement Agrument and General Rd-ease 

Defendants with five (5) days to cure with curing period triggered by the above- referenced email. If Defendants do not cure within five (S) day period, Plaintiff shall be entitled to: 

a. An automatic judgment Gointly and severally) for the total amount of the

settlement mjnus payments made plus $10,000. In liquidated damages; or (at Plaintiff's choice); 

b. Reinstatement of the cause of action to the Court's docket to proceed to trial.

Pursuant to Lynn's Food Stores, Inc. v. U.S. Dep 't. of l.Abor, 619 F.2d 1350, 1352 (11th 

Cir. 1982), the Parties shall jointly move the Court through Plaintiff filing a Joint Motion for 

Approval and Proposed Order Dismissing this case with prejudice and jointly ask the Court to 

approve the terms of this Settlement Agreement, dismiss the Litigation with prejudice, to retain 

jurisdiction to enforce the tenns of this Settlement Agreement, and for each side to bear its own 

fees and costs except as set forth herein. 

Nothing in this Agreement prohibits Plaintiff from filing a charge or complaint 

with, or from participating in an investigation or proceeding conducted by the EEOC, the National 

Labor Relations Board ("NLRB"), the Florida Commission on Human Relations ("FCHR"), or 

any similar federal, state, or local agency. Plaintiff, however, waives, foregoes, and relinquishes 

the recovery of any legal and/or equitable relief that she may claim, or receive, or that any 

individual or entity may seek or recover on Plaintiff's behalf, in conjunction with any charge, 

investigation, or proceeding conducted by or before the EEOC, NLRB, FCHR, or any similar 

federal, state, or local agency. 

3. Indemnjfication. Plaintiff acknowledges and agrees that it shall be solely and

exclusively Plaintifrs obligation and responsibility to report to the appropriate

governmental agencies and other authorities all monies received as wages and/or other

compensation under this Agreement and to report and pay all related taxes or impositions.

Plaintiff shall indemnify and bold harmless Defendants, its directors, officers, owners,

employees, subsidiaries and affiliates from and against any and all claims, damages,

losses, liabilities, obligations asserted, imposed, and/or threatened against Defendants by

any person or entity relating, directly or indirectly, to the monies received by Plaintiff

hereunder as wages and/or other compensation, including, without limitation, Plaintiff,

the IRS, or any other person.

4. Attorneys Not Tax Experts, The Parties acknowledge that the attorneys involved

in this Settlement Agreement or the Litigation do not claim to be experts in tax matters.

The Parties further acknowledge and agree that they have neither received nor relied on

any tax advice or information from any attorney involved in negotiating this Settlement

Agreement or the Litigation or in negotiating of this Settlement Agreement.

5. Nop-Admjssjop Clause, By entering into this Agreement, Plaintiff and Defendant

acknowledge and agree that nothing in this Settlement Agreement is meant to suggestthat

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 4

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 4 of 10
Settlement AgreemenJ and General Rdease 

Defendants have violated any law or contract or that Plaintiff has any claim against 

Defendants. Defendant explicitly denies any violation oflaw, including any liability under 

the FLSA. Plaintiff agrees and understands that the amounts paid by or on behalf of 

Defendants pursuant to this Agreement are being paid strictly and solely for purposes of 

settlement and that Defendant expressly and vigorously denies that Plaintiff is entitled to 

receive any relief whatsoever. The Parties agree and acknowledge that there are good faith, 

bona fide disputes between Plaintiff and Defendants, including whether Plaintiff is entitled 

to receive any damages. The Parties further agree and acknowledge that this Settlement 

Agreement represents a fair, reasonable, good faith, and arms-length resolution of disputed 

issues and claims. Plaintiff represents, warrants, and acknowledges that Defendants do not 

owe her any wages, other c-ompensation, or payments of any kind or natu

re, other than as 

set forth in this Settlement Agreement. 

6. Non-Disparagement. Plaintiff agrees not to make critical, negative, or

disparaging remarks to others about Defendants, its business, products, services, clients,

or agents. She also agrees not to disclose personal or private information about

Defendants, its business, products, services, employees, or agents. Plaintiff agrees she will

not encourage, directly or indirectly, any current employee of Defendants to cease

employment with Defendants. Plaintiff further agrees that, with the exception of her

participation in any government investigation or responsive to a subpoena, that Plaintiff

will not encourage, directly or indirectly, instruct, or otherwise cause or assist any current

or former employee to commence any lawsuit or government investigation against

Defendants. Plaintiff agrees she will not encourage, directly or indirectly, or otherise w

cause any current or former client, or business associate of Defendants to cease working

with Defendants. Plaintiff understands and agrees that breach of this provision of the

contract represents a material breach. The Defendants' Control Group, which is comprised

of the current owners, officers, and managers of Defendant companies (the "Control

Group"), agree that they will not make demeaning, disparaging, and/or derogatory

remarks to third parties regarding Plaintiff.

7. Neutral Befeceuce: In the event that a prospective employer requests an

employment reference for Plaintiff, the Parties agree that Defendant shall not be required

to provide anything more than dates of employment, position held by Plaintiff while

working for Defendant, and her rate of pay. The Defendants agree to not disparage

Plaintiff during such communications or to inform the contacting party of Plaintiff's

lawsuit or the underlying facts leading up to or the existence or substance of this

Settlement Agreement and General Release.

8. No Be-Dice/ N0;Rejpst,atement. Plaintiff agrees never to apply for employment

and/or seek work directly or indirectly with Defendants or any business owned by or

contracted by Defendants, and/or any of its predecessors, successors and assigns, parent

companies, subsidiary companies, affiliated corporations, or those owned by the same

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 5

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 5 of 10
Settlement Agreement and General Release 

owners as Defendants. Plaintiff agrees that this forbearance to seek future employment is 

purely contractual and is in no way involuntary, discriminatory, or retaJiatory. In

consideration for the payments made by Defendants under this Agreement, and in light of 

the irreconcilable differences between Plaintiff and Defendants, Plaintiff acknowledges 

and agrees that she is not entitled to, and will not accept, reemployment or reinstatement of 

employment with Defendants or any business owned, managed, or operated by Defendants. 

Plaintiff agrees that Defendants' refusal to rehire or employ her will not subject Defendants 

to liability on any grounds. Plaintiff is permanently trespassed from any location owned, 

managed, or operated by Defendants or any of the same owners as Defendants. Should 

Plaintiff and/or Defendants discover that Plaintiff has violated this Paragraph, Plaintiff wi II 

immediately resign and/or Defendant(s) will immediately terminate the employment 

relationship and Plaintiff shall be entitled to be paid for all hours worked prior to 

termination. 

9. Representation by the Plaintiff. Plaintiff represents that, as of the date that this

Agreement is executed, she is not aware of any additional claims that she may have against

any of the Released Parties, and the Plaintiff hereby certifies that she has not filed any

claim (except the Litigation), and do not intend to file any claims, demands, liabilities,

and/or causes of action against any of the Released Parties for actions that occurred prior

to the date of this Settlement Agreement, related to her employment, and/ or involving

Plaintiff's employment, other than claims to enforce this Agreement.

10. Bindine Nature of Aereement; This Agreement shall be binding upon each of

the Parties and upon their respective heirs, administrators, representatives, executors,

successors, and assigns, and shall inure to the benefit of each Party and to their respective

heirs, administrators, representatives, executors, successors, and assigns.

11. Jurisdictjon, The Parties agree that jurisdiction over this matter shall be in the

United States District Court for the Southern District of Florida, which is presiding over

the Litigation. The Agreement is governed by the substantive law of the State of Florida,

and where applicable, federal law. If the District Court chooses not to retain jurisdiction,

then this Agreement shall be enforceable in the appropriate court in Broward County,

Florida. In any action or proceeding, including but not limited to appellate proceedings,

relating to or arising out of this Settlement Agreement, the Parties agree that the Court

specifically reserves the right to award attorney's fees for enforcement of the Settlement

Agreement.

12. Jury Waiver. Each party expressly waives any right to have any dispute arising

out of this Agreement tried by a jury.

,oaa.yFycR0e7••-••A81°' __ Stacy A. Hi TA.STERJTE, C. _/_V_ L1.wt l � / /

A:!_ PUERTO SECO, INC. ynden Gordon.M'ennifer Clarke 

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 6

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 6 of 10
St:ttJonenl Agr�nl and Genera/ Release 

13. Seyerabjljty. In the event that one or more terms or provisions of this Agreement

are found to be invalid or unenforceable for any reason or to any extent, each remaining

term and provision shall continue to be valid and effective and shall be enforceable to the

fullest extent pennitted by law.

14. Eptire Aecceroeut. This Agreement constitutes the complete understanding of

the Parties hereto and supersedes any and all prior agreements, promises,

representations, or inducements, whether oral or written, concerning its subject matter.

No promises or agreements made subsequent to the execution of this Agreement by

these Parties shall be binding unless reduced to writing and signed by an authorized

representative of each party.

15. Enforcement The Parties stipulate that the Court shall retain jurisdiction to

enforce this Settlement Agreement and General Release. In the event any action is

commenced to enforce said Settlement Agreement or for a proven breach of this

Agreement, the prevailing party shall be entitled to reasonable fees and costs incurred by

the party (through and including appeals).

16. Voluntuipess. The Parties certify that they have fully read, negotiated, and

completely understand the provisions of this Agreement, that each Party has been advised

by the other to consult with an attorney before signing the Agreement, and that each Party

is signing freely and voluntarily, and without duress, coercion, or undue influence. The

Parties each acknowledge that she/it/they are entering into this Agreement freely and

voluntarily and with complete understanding of all the rights she/ it/they is/are waiving in

this Settlement Agreement and of the irrevocable nature of same. Plaintiff and Defendants

acknowledge that they have consulted with counsel of their own choosing before

executing this Settlement Agreement.

17. Coupterparts: This Agreement may be executed in multiple counterparts, each of

which shall constitute an original, and all of which shall constitute one single Agreement.

Faxed transmfasions and/or copies of the signature block shall be deemed enforceable.

18. AcknowJedments and Affirmations, Plaintiff affirms that she has not filed,

or presently is a party to any charge or investigation against Releasees with any federal

or local agency. Plaintiff further waives the rights and claims set forth above in 

paragraph l and agrees not to institute, or have instituted by anyone, a lawsuit against 

the Releasees based on any such claims or rights. 

19. Construction Plaintiff and Defendant have jointly participated in the

negotiation of this Agreement and this Agreement is the product of joint draftsmanship

IDIICll¥ 7""Y11111Af1DI __ Stacy A. Hi TASTE RITE, G( a_v_ [.))_I� l 

fa � /.../ -- P

UERTO SECO, IN . ynden Gordon.�Jennifer Clarke 

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 7

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 7 of 10
Settlement Agreement and General Release 

by the Parties. In the event of an ambiguity or question of intent or interpretation arises, 

this Agreement shall be construed as if it was drafted jointly by the Parties and no 

presumptions or burdens of proof shall arise favoring any party by virtue of authorship of 

this Agreement. 

20. Qeadjpgs. The Parties agree that the headings used in this Settlement Agreement

are for convenience and reference only and in no way define, describe, extend, or limit

the scope or intent of this Agreement or the intent of any provision in it.

21. Cooperation. The Parties agree to cooperate fully in the execution of any

documents or perfonnance in any way which may be reasonably necessary to carry out

the purposes of this Agreement and to effectuate the intent of the Parties hereto.

22. Repcesentatjops. By signing this Agreement the Parties represent that they have

read this entire document and understands all of its terms. 

NOTWITHSTANDING THE ABOVE, PLAINTIFF ACKNOWLEDGES THAT 

SHE IS NOT RELEASING: ANY CLAIM THAT RELATES TO ANY RIGHTS SHE 

MIGHT HA VE TO FD.,E A CLAIM FOR UNEMPLOYMENT COMPENSATION OR TO 

VESTED BENEFITS UNDER ANY EMPLOYEE RETIREMENT PLAN 

SPONSORED BY DEFENDANT(S); ANY RJGHTS OR CLAJMS THAT MAY ARISE 

AFTER TIDS AGREEMENT IS SIGNED; ANY RIGHTS OR CLAIMS TBA T BY LAW 

CANNOT BE RELEASED IN THIS AGREEMENT; OR ANY RIGHTS OR CLAIMS TO 

ENFORCE THIS AGREEMENT. 

The Plaintiff expressly represents and warrants that she (a) has carefully read this 

Settlement Agreement; (b) fully understands the terms, conditions, and significance of this 

Settlement Agreement; (c) has had ample time to consider and negotiate this Settlement 

Agreement; (d) has had a full opportunity to review this Settlement Agreement with her attorneys, 

and has done so; and has (e) executed this Settlement Agreement-consisting of 23 numbered 

paragraphs and a total of 9 pages, voluntarily, knowingly, and with the advice of counsel. 

{Space Intentionally Lefl Blank/ 

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 8

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 8 of 10
Settlement Agreement and General Release 

The parties knowingly and voluntarily sign this Settlement Agreement and General

Release as of the date(s) set forth below:

STACY A. HILL 

STACY A. BlLL 

Date: __ 1

_

0_

11

_

6_

/2_

0_

20 ______ _

By:_.;_,,,......;;.;.;.-ic.=.:..�---,1.-----,--

Name: - 50 �'DN 

TW� � 

Date: / o - / J - � 

JENNIFER CLARKE 

s;gned:�6i== Date: �J-' 

!Mu& I � )_�,.,._.,,.,...,, .. ,..,,,. Stacy A. Hill. ___ TASTE RITE, INC. __ 

/ �--PUERTO SECO, lNC. Lynden Gordon. /2:::)ennifer Clarke

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 9

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 9 of 10
eSignature Details 

Signer ID: 

Signed by: 

Sent to email: 

IP Address: 

Signed at: 

BCbyFyERQg7FfizVRB1AgtD6 

Stacy A Hill 

hi11stacy27@yahoo.com 

99.90.52.96 

Oct 16 2020, 10:37 am EDT 

Exhibit A 

Joint Motion for Approval of Settlement 

Agreement and Dismissal of Case with Prejudice - 10

Case 0:20-cv-61445-RAR Document 21-1 Entered on FLSD Docket 10/16/2020 Page 10 of 10