EXHIBIT A

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SETTLEMENT AGREEMENT AND RELEASE

THIS SETTLEMENT AGREEMENT AND RELEASE (“Agreement”) is made by and 

between James Brand, Barry Farmer, Mark Graham, Kevin Jackson, Michael 

Jackson, Jose Vigil, and Christopher Woodard (“Plaintiffs”); and Comcast Cable 

Communications Management, LLC, for itself and on behalf of its parents, 

subsidiaries, and corporate affiliates (“Defendants” or “Comcast”). Plaintiffs and 

Defendants are referred to collectively as the “Parties.” 

1. The Lawsuit. On February 16, 2012, Plaintiffs filed a lawsuit against 

Defendants in the United States District Court for the Northern District of Illinois, 

entitled James Brand, et al. v. Comcast Corporation, et al., Case No. 12-C-1122 (the 

“Lawsuit”).

2. Recitals. In the Lawsuit, Plaintiffs made certain allegations concerning 

Comcast’s alleged failure to pay them for hours worked in purported violation of 

the FLSA, IMWL and IWPCA. Comcast has denied, and continues to deny, all of 

the claims asserted in the Lawsuit, denies any and all liability or wrongdoing of any 

kind whatsoever associated with any of the facts or claims alleged in the Lawsuit 

and by Plaintiffs, and makes no concession or admission of wrongdoing or liability 

of any kind whatsoever. The Parties and their counsel have considered that under 

the circumstances and in light of the costs, distractions to Comcast’s business, and 

risks of litigation, their respective interests are best served by compromise, 

settlement and dismissal of the Lawsuit with prejudice and have concluded that 

the terms of this Agreement are fair, reasonable and adequate. The Parties 

participated in arm’s length settlement discussions and mediation supervised by 

Michael E. Dickstein of Dickstein Dispute Resolution/MEDiate, and as a result of 

these settlement discussions and mediation, have agreed to settle the issues, 

matters and things in dispute between and among them pursuant to the terms of 

this Agreement. The Parties, through their counsel, will seek judicial approval of this 

Agreement. 

3. Payment of Money. As consideration for the promises and releases in 

this Agreement, Defendants agree to pay Plaintiffs the gross amount of Four 

Hundred Fifty Thousand and 00/100 Dollars ($450,000.00) (the “Gross Settlement 

Payment”), as follows:

A. Payment 1 – Plaintiffs’ Payments – Two Hundred Thousand and 00/100 

Dollars ($200,000.00)

No later than thirty (30) calendar days after the Court approves this 

Agreement, and upon receipt of an executed Form W-9 for each Plaintiff,

Defendants agree to pay Plaintiffs the gross sum of Two Hundred Thousand and 

00/100 Dollars ($200,000.00), allocated and distributed as follows: 

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(1) Twenty-Three Thousand Three Hundred Thirty-Seven and 50/100 

Dollars ($23,337.50), minus applicable taxes and withholdings 

required by law, via a check or checks as set forth below made 

payable to James Brand and delivered to Noelle Brennan & 

Associates, Ltd. Of this amount, fifty percent (50%), or $11,668.75, is 

for claimed lost wages and will be treated by the Parties as wages 

for tax purposes, and shall be subject to required withholdings and 

deductions so the net amounts payable will be less than the gross 

amounts, and reported to the Internal Revenue Service on a Form W2. The remaining fifty percent (50%), or $11,668.75, is for claimed 

penalties, liquidated damages, interest, and all other non-wage 

income and will be reported to the Internal Revenue Service on a 

Form 1099.

(2) Thirty-Six Thousand Six Hundred Twenty-Four and 82/100 Dollars 

($36,624.82), minus applicable taxes and withholdings required by 

law, via a check or checks as set forth below made payable to Barry 

Farmer and delivered to Noelle Brennan & Associates, Ltd. Of this 

amount, fifty percent (50%), or $18,312.41, is for claimed lost wages 

and will be treated by the Parties as wages for tax purposes, and 

shall be subject to required withholdings and deductions so the net 

amounts payable will be less than the gross amounts, and reported 

to the Internal Revenue Service on a Form W-2. The remaining fifty 

percent (50%), or $18,312.41, is for claimed penalties, liquidated 

damages, interest, and all other non-wage income and will be 

reported to the Internal Revenue Service on a Form 1099.

(3) Ten Thousand Fifty-Nine and 81/100 Dollars ($10,059.81), minus 

applicable taxes and withholdings required by law, via a check or 

checks as set forth below made payable to Mark Graham and 

delivered to Noelle Brennan & Associates, Ltd. Of this amount, fifty 

percent (50%), or $5,029.91, is for claimed lost wages and will be 

treated by the Parties as wages for tax purposes, and shall be 

subject to required withholdings and deductions so the net amounts 

payable will be less than the gross amounts, and reported to the 

Internal Revenue Service on a Form W-2. The remaining fifty percent 

(50%), or $5,029.90, is for claimed penalties, liquidated damages, 

interest, and all other non-wage income and will be reported to the 

Internal Revenue Service on a Form 1099.

(4) Forty-Three Thousand Five Hundred Forty-Nine and 41/100 Dollars 

($43,549.41), minus applicable taxes and withholdings required by 

law, via a check or checks as set forth below made payable to 

Kevin Jackson and delivered to Noelle Brennan & Associates, Ltd. Of 

this amount, fifty percent (50%), or $21,774.71, is for claimed lost 

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wages and will be treated by the Parties as wages for tax purposes, 

and shall be subject to required withholdings and deductions so the 

net amounts payable will be less than the gross amounts, and 

reported to the Internal Revenue Service on a Form W-2. The 

remaining fifty percent (50%), or $21,774.70, is for claimed penalties, 

liquidated damages, interest, and all other non-wage income and 

will be reported to the Internal Revenue Service on a Form 1099.

(5) Thirty-Three Thousand Five Hundred Fifty-Seven and 37/100 Dollars 

($33,557.37), minus applicable taxes and withholdings required by 

law, via a check or checks as set forth below made payable to 

Michael Jackson and delivered to Noelle Brennan & Associates, Ltd. 

Of this amount, fifty percent (50%), or $16,778.69 is for claimed lost 

wages and will be treated by the Parties as wages for tax purposes, 

and shall be subject to required withholdings and deductions so the 

net amounts payable will be less than the gross amounts, and 

reported to the Internal Revenue Service on a Form W-2. The 

remaining fifty percent (50%), or $16,778.68, is for claimed penalties, 

liquidated damages, interest, and all other non-wage income and 

will be reported to the Internal Revenue Service on a Form 1099.

(6) Forty-Three Thousand Seven Hundred Forty-Four and 12/100 Dollars 

($43,744.12), minus applicable taxes and withholdings required by 

law, via a check or checks as set forth below made payable to Jose 

Vigil and delivered to Noelle Brennan & Associates, Ltd. Of this 

amount, fifty percent (50%), or $21,872.06, is for claimed lost wages 

and will be treated by the Parties as wages for tax purposes, and 

shall be subject to required withholdings and deductions so the net 

amounts payable will be less than the gross amounts, and reported 

to the Internal Revenue Service on a Form W-2. The remaining fifty 

percent (50%), or $21,872.06, is for claimed penalties, liquidated 

damages, interest, and all other non-wage income and will be 

reported to the Internal Revenue Service on a Form 1099.

(7) Nine Thousand One Hundred Twenty-Six and 97/100 Dollars 

($9,126.97), minus applicable taxes and withholdings required by 

law, via a check or checks as set forth below made payable to 

Christopher Woodard and delivered to Noelle Brennan & Associates, 

Ltd. Of this amount, fifty percent (50%), or $4,563.49, is for claimed 

lost wages and will be treated by the Parties as wages for tax 

purposes, and shall be subject to required withholdings and 

deductions so the net amounts payable will be less than the gross 

amounts, and reported to the Internal Revenue Service on a Form W2. The remaining fifty percent (50%), or $4,563.48, is for claimed 

penalties, liquidated damages, interest, and all other non-wage 

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income and will be reported to the Internal Revenue Service on a 

Form 1099.

B. Payment 2 – Attorneys’ Fees and Costs – Two Hundred Fifty Thousand and 

00/100 Dollars ($250,000.00)

No later than thirty (30) calendar days after the Court approves this 

Agreement, and upon receipt of an executed Form W-9 for each business, 

Defendants agree to pay Plaintiffs’ attorneys of record (“Plaintiffs’ Counsel”) the 

gross sum of Two Hundred Fifty Thousand and 00/100 Dollars ($250,000.00), 

allocated and distributed as follows: 

(1) One Hundred Twenty-Three Thousand Seven Hundred Sixty-Six and 

41/100 Dollars ($123,766.41), via a check made payable and 

delivered to Noelle Brennan & Associates, Ltd. This amount is for 

attorneys’ fees and costs and will be reported to the Internal 

Revenue Service on a Form 1099.

(2) One Hundred Twenty-Six Thousand Two Hundred Thirty-Three and 

59/100 Dollars ($126,233.59), via a check made payable and 

delivered to Stephan Zouras LLP. This amount is for attorneys’ fees 

and costs and will be reported to the Internal Revenue Service on a 

Form 1099.

To the extent the Court disallows, disapproves, or reduces the award of 

attorneys’ fees and costs as currently allocated to Plaintiffs’ Counsel, the 

settlement will proceed, and this Agreement will be modified to reflect the amount 

of attorneys’ fees and costs approved by the Court. Any amounts allocated as 

attorneys’ fees and costs under this Agreement but not approved by the Court 

shall be allocated to the Plaintiffs’ Payments, in which case new Plaintiffs’ 

Payments will be calculated.

4. Tax Liabilities. Defendants agree that they are solely responsible for 

payment of the employer’s share of all payroll taxes on that portion of the Gross 

Settlement Payment being treated as wages (as set forth in paragraphs 3(A)((1)-

(7)) above) and reported on a Form W-2. Defendants also bear sole responsibility 

for remitting to the appropriate tax authorities all taxes withheld from the payments 

to Plaintiffs. For their part, Plaintiffs bear sole responsibility for the payment of all 

federal, state and local taxes, of any type whatsoever, resulting from their receipt 

of the payments provided for above. As to the Plaintiffs’ Payments reported as 

non-wage income, the Plaintiffs agree to indemnify and hold Comcast harmless 

for any taxes due or owing by the Plaintiffs on such payments. Any amounts paid 

to the Plaintiffs shall not create any credit or otherwise affect the calculation of 

any deferred compensation, benefit, pension, or other compensation or benefit 

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plan provided by any of the Released Parties (as that term is defined in Paragraph 

6).

5. Approval Order and Dismissal With Prejudice. The Parties agree to 

work to effectuate approval and dismissal of the Action with the Court. To that 

end, promptly upon execution of this Agreement, Plaintiffs’ Counsel will prepare a 

Joint Motion for Approval of FLSA Settlement and will provide it to Comcast’s 

counsel for review, comment, or revisions ten (10) business days in advance of 

applicable deadlines (but not later than June 13, 2016) for filing. The Joint Motion 

shall seek the entry of an Order approving the terms of this Agreement, including 

of the Plaintiffs’ Released Claims and approving the payment of attorneys’ fees 

and costs. The Parties agree to cooperate with one another and execute any 

additional documents which may be necessary to secure dismissal of the Lawsuit 

with prejudice, each party to bear its own costs and attorney’s fees except as 

otherwise stated in this Agreement. In the event this Agreement is not approved 

by the Court, this Agreement will no longer have any effect and the Parties will 

revert to litigating the Lawsuit as of the date and time immediately prior to the 

execution of this Agreement. Plaintiffs and Plaintiffs’ Counsel may not cite this 

Agreement in the Lawsuit or any other action or proceeding.

6. Plaintiffs’ Released Claims. In exchange for the payments and 

benefits described herein, Plaintiffs release and discharge Comcast and its current, 

former, and future corporate affiliates and related entities including, without 

limitation, parents, subsidiaries, predecessors, successors, divisions, joint ventures 

and assigns, and each of these entities’ past or present directors, officers, 

employees, partners, members, principals, agents, insurers, co-insurers, re-insurers, 

benefit plans, plan administrators, shareholders, attorneys, and personal or legal 

representatives (“Released Parties”) from all claims, demands, causes of action, 

fees and liabilities of any kind whatsoever, whether known or unknown, whether 

contingent or non-contingent, specifically asserted or not, which the Plaintiffs ever 

had, now have, or may have against any of the Released Parties by reason of any 

act, omission, transaction, practice, plan, policy, procedure, conduct, occurrence, 

or other matter, up to and including the date the Court approves this Agreement, 

related to the payment of wages, commissions, shift differentials, bonuses, and/or 

other compensation that were or could have been asserted in the Litigation, 

including those claims that could arise under the Fair Labor Standards Act (FLSA), 

29 U.S.C. § 201, et seq. , the Illinois Minimum Wage Law (IMWL), 820 ILCS 105/1, et 

seq., the Illinois Wage Payment and Collection Act (IWPCA), 820 ILCS 115/1, et 

seq., or any other state or local wage/hour and wage payment statute/ordinance 

for any type of relief, including without limitation, minimum wages, overtime or 

other wages; unpaid wages or other compensation, costs; wage deductions; 

premium pay; liquidated damages, penalties; punitive damages; interest; 

attorneys’ fees and; litigation costs; restitution; and equitable relief. In waiving and 

releasing the claims set forth in this Agreement, whether or not now known to 

Plaintiffs, Plaintiffs understand that this means that, if Plaintiffs later discover facts 

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different from or in addition to those facts currently known or believed to be true 

by Plaintiffs, the waivers and releases of this Agreement will remain effective in all 

respects – despite such different or additional facts and even if Plaintiffs would not 

have agreed to release the claims if Plaintiffs had prior knowledge of such facts. 

7. Limitations on Releases. The releases in this Agreement expressly 

exclude claims that cannot be released by law and claims to vested benefits, 

workers’ compensation, or unemployment benefits.

8. No Admission of Liability. Comcast has denied and continues to 

deny, specifically and generally, the claims asserted in the Lawsuit, any and all 

liability or wrongdoing of any kind whatsoever associated with any of the facts or 

claims alleged in the Lawsuit. Comcast maintains that Plaintiffs and all other 

individuals who provided services to Comcast as Line Technicians were properly 

and fully compensated for all of the time they worked for Comcast. Pursuant to 

Federal Rule of Evidence 408, and any other analogous rules of evidence that are 

applicable, neither the settlement memorialized in this Agreement, nor any act 

performed or document executed pursuant to, or in furtherance of, the settlement 

memorialized in this Agreement: (a) is or may be deemed to be or may be used as 

an admission or evidence of, the validity of any claims released in this Agreement, 

or of any wrongdoing or liability of the Released Parties; or (b) is or may be 

deemed to be or may be used as an admission or evidence of, any fault or 

omission of the Released Parties, in any civil, criminal or administrative proceeding 

in any court, administrative agency, or other tribunal.

9. Plaintiffs’ Counsel’s Acknowledgment. Plaintiffs’ Counsel represent that 

other than the Plaintiffs, Plaintiffs’ Counsel does not have any other current clients 

who have wage and hour claims against any of the Released Parties in 

connection with their work for Comcast as Line Technicians. Additionally, Plaintiffs’ 

Counsel are not aware of any individuals who work or worked for Comcast 

contemplating wage and hour claims against any of the Released Parties.

10. Confidentiality. Plaintiffs’ Counsel will not directly or indirectly 

reference this Agreement (including its terms, negotiations, and amounts of 

payments) or this litigation on any website, through any form of social media, in 

any press release, or in any media outlet or to any member of the media. If the 

media inquires about this litigation or the settlement, the response will be limited to

“the matter has been resolved.” Plaintiffs will strictly maintain the confidentiality of 

the fact and terms of the settlement and will not discuss the settlement with the 

press, on any website, social media, or any other media outlet or generally with 

any member of the public. Notwithstanding the foregoing, Plaintiffs and Plaintiffs’ 

Counsel may disclose information concerning this Agreement to their respective 

immediate family members, counsel, and tax advisors who have first agreed to 

keep said information confidential and not to disclose it to others. Notwithstanding 

the foregoing, Plaintiffs and Plaintiffs’ Counsel are not prohibited or restricted from 

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disclosures that are required by law or as may be necessary to enforce the 

Agreement. To the extent any such disclosures are required, and to the extent 

permitted by law, Plaintiffs and Plaintiffs’ Counsel shall provide Comcast with as 

much notice as possible of any request to make any above-described disclosure, 

and will use best efforts to ensure any such disclosure will occur in a manner 

designed to maintain confidentiality of this Agreement to the fullest extent 

possible. 

11. Consequences for Breach of Confidentiality Obligations. Plaintiffs 

recognize and agree that the representations, promises, and covenants set forth in 

Paragraph 10 relating to their confidentiality obligations constitute a material and 

significant part of the consideration received from the Released Parties in 

exchange for their obligations under this Agreement, and that any violation of 

Paragraph 10 will constitute a material violation of this Agreement. Plaintiffs agree 

that they will each be liable for liquidated damages in the amount of twenty-five 

percent (25%) of their individual Plaintiff Payment if they violate this confidentiality 

obligation. Further, if Plaintiffs or Plaintiffs’ Counsel violate this confidentiality 

provision prior to the Court’s approval of the settlement, Comcast may rescind the 

settlement, rendering it null and void, and will no longer be bound by any of its 

terms. If settlement is not approved or Comcast withdraws from the settlement 

due to a violation of the confidentiality provisions, this Agreement will become null 

and void except for the terms of Paragraph 10.

12. Choice of Law. The Agreement will be construed and governed by the 

laws of the State of Illinois without reference to conflict of law rules.

13. The Court’s Retention of Jurisdiction. Following its approval of the 

Agreement, the Court will retain jurisdiction to enforce Paragraph 10 and other 

terms of the Parties’ settlement.

14. Modification. This Agreement and its attachments may not be 

changed, altered, or modified, except in a writing signed by Comcast and 

Plaintiffs’ Counsel on behalf of themselves and Plaintiffs.

15. Entire Agreement and Severability. This Agreement constitutes the 

entire agreement between the Parties concerning the subject matter hereof. No 

extrinsic oral or written representations or terms shall modify, vary or contradict the 

terms of this Agreement. In the event of any conflict between this Agreement and 

any other document related to the Parties’ settlement of the Litigation, the Parties 

intend that this Agreement shall be controlling.

16. Defendants’ Authority to Enter Into Agreement. The individual signing this 

Agreement on behalf of Comcast represents and warrants that he/she is duly 

authorized to execute this Agreement on behalf of and to bind each entity.

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17. Signatures. Signatures via facsimile or scanned electronically will be 

treated as originals. Signatures will not require a notary. This agreement may be 

signed in counterparts.

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ACKNOWLEDGEMENT

I HAVE CAREFULLY READ ALL OF THE PROVISIONS OF THIS CONFIDENTIAL 

SETTLEMENT AGREEMENT AND RELEASE OF CLAIMS AND UNDERSTAND THAT IT 

RELATES TO MY LEGAL RIGHTS. I HAVE BEEN GIVEN AN ADEQUATE OPPORTUNITY TO 

CONSULT WITH AN ATTORNEY AND TO REVIEW THE AGREEMENT. I ACKNOWLEDGE 

THAT:

a. NEITHER COMCAST NOR ITS REPRESENTATIVES MADE ANY 

REPRESENTATIONS CONCERNING THE TERMS OR EFFECT OF THIS 

AGREEMENT OR RELEASE OTHER THAN AS SET FORTH IN THIS 

DOCUMENT; 

b. THIS AGREEMENT WAS MUTUALLY NEGOTIATED AND NO PROVISION 

OF THIS AGREEMENT WILL BE CONSTRUED AGAINST OR INTERPRETED 

TO THE DISADVANTAGE OF COMCAST BY REASON OF COMCAST 

HAVING DRAFTED OR STRUCTURED ANY PROVISION;

c. I HAVE VOLUNTARILY SIGNED THIS AGREEMENT AS MY OWN FREE 

ACT WITH FULL KNOWLEDGE OF ITS TERMS AND CONDITIONS, WHICH 

ARE FINAL AND BINDING UPON ME.

d. IN SIGNING THIS AGREEMENT, I HAVE NOT RELIED UPON ANY 

REPRESENTATION, PROMISE OR STATEMENT, WRITTEN OR ORAL, NOT 

SET FORTH IN THIS DOCUMENT.

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I HEREBY AGREE TO THE TERMS SET FORTH ABOVE:

JAMES BRAND

By: 

Date: 

BARRY FARMER:

By: 

Date: 

MARK GRAHAM

By: 

Date: 

KEVIN JACKSON

By: 

Date: 

MICHAEL JACKSON

By: 

Date: 

JOSE VIGIL

By: 

Date: 

CHRISTOPHER WOODARD

By: 

Date: 

DocuSign Envelope ID: 6BBD3625-90FF-4922-8A31-923944E568D1

6/15/2016

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I HEREBY AGREE TO THE TERMS SET FORTH ABOVE:

JAMES BRAND

By: 

Date: 

BARRY FARMER:

By: 

Date: 

MARK GRAHAM

By: 

Date: 

KEVIN JACKSON

By: 

Date: 

MICHAEL JACKSON

By: 

Date: 

JOSE VIGIL

By: 

Date: 

CHRISTOPHER WOODARD

By: 

Date: 

DocuSign Envelope ID: 0321ED49-7BD0-4FC2-B049-9DFD76F3778D

6/15/2016

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I HEREBY AGREE TO THE TERMS SET FORTH ABOVE:

JAMES BRAND

By: 

Date: 

BARRY FARMER:

By: 

Date: 

MARK GRAHAM

By: 

Date: 

KEVIN JACKSON

By: 

Date: 

MICHAEL JACKSON

By: 

Date: 

JOSE VIGIL

By: 

Date: 

CHRISTOPHER WOODARD

By: 

Date: 

DocuSign Envelope ID: 3CD68A83-9998-4296-B6F6-FD0EE9607DA2

6/17/2016

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I HEREBY AGREE TO THE TERMS SET FORTH ABOVE:

JAMES BRAND

By: 

Date: 

BARRY FARMER:

By: 

Date: 

MARK GRAHAM

By: 

Date: 

KEVIN JACKSON

By: 

Date: 

MICHAEL JACKSON

By: 

Date: 

JOSE VIGIL

By: 

Date: 

CHRISTOPHER WOODARD

By: 

Date: 

DocuSign Envelope ID: BEFC47FC-200B-4B29-8603-63BD815830DF

6/15/2016

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I HEREBY AGREE TO THE TERMS SET FORTH ABOVE:

JAMES BRAND

By: 

Date: 

BARRY FARMER:

By: 

Date: 

MARK GRAHAM

By: 

Date: 

KEVIN JACKSON

By: 

Date: 

MICHAEL JACKSON

By: 

Date: 

JOSE VIGIL

By: 

Date: 

CHRISTOPHER WOODARD

By: 

Date: 

DocuSign Envelope ID: 4559C5D7-2D64-4D5E-9AD8-B31FBE0F31EF

6/15/2016

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I HEREBY AGREE TO THE TERMS SET FORTH ABOVE:

JAMES BRAND

By: 

Date: 

BARRY FARMER:

By: 

Date: 

MARK GRAHAM

By: 

Date: 

KEVIN JACKSON

By: 

Date: 

MICHAEL JACKSON

By: 

Date: 

JOSE VIGIL

By: 

Date: 

CHRISTOPHER WOODARD

By: 

Date: 

DocuSign Envelope ID: 9043356C-4AF7-41AA-A98C-E4033E05D318

6/15/2016

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I HEREBY AGREE TO THE TERMS SET FORTH ABOVE:

JAMES BRAND

By: 

Date: 

BARRY FARMER:

By: 

Date: 

MARK GRAHAM

By: 

Date: 

KEVIN JACKSON

By: 

Date: 

MICHAEL JACKSON

By: 

Date: 

JOSE VIGIL

By: 

Date: 

CHRISTOPHER WOODARD

By: 

Date: 

DocuSign Envelope ID: 74789E06-659F-4A39-835B-5D89E00F549D

6/16/2016

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