Exhibit A

Case 2:15-cv-02563-SMM Document 103-1 Filed 07/09/20 Page 1 of 8
Confidential

Page 1 of 7

41023039v2

CONFIDENTIAL SETTLEMENT AGREEMENT AND 

COMPREHENSIVE RELEASE OF ALL CLAIMS

This Confidential Settlement Agreement and Comprehensive Release of All Claims 

(“Agreement”) is made by and between Jane Strong (“Claimant”) and Stetson Desert Project, 

LLC, d/b/a Lé Girls Cabaret, Cory J. Anderson and Cary Anderson (referred to collectively 

herein as “Defendants”), all of whom are collectively referred to as the “Parties,” or individually 

referred to as a “Party.”

RECITALS

WHEREAS, Claimant alleges she was employed by some or all of the Defendants;

WHEREAS, Defendants deny that Claimant ever was an employee of Defendants, or any 

of them, and assert that she was a bona fide licensee and independent entertainer appearing at Lé 

Girls;

WHEREAS, Claimant alleges that she is entitled to payment of certain past-due amounts, 

pursuant to contract, federal and state wage law, and common law; 

WHEREAS, Defendants maintain that Claimant was a licensee/independent entertainer at 

Lé Girls not covered by any employment laws;

WHEREAS, Claimant is a plaintiff in a lawsuit filed in the United States District Court 

for the District of Arizona, captioned Jane Roe Dancer v. Stetson Desert Project LLC d/b/a/ Lé 

Girls Cabaret, et al., No. 2:16-cv-00408-SMM (the “Lawsuit”);

WHEREAS, Defendants expressly deny any liability with respect to Claimant’s

allegations in the Lawsuit; and

WHEREAS, the Parties, having conducted discovery, wish to resolve any and all 

disputes, claims, complaints, grievances, charges, actions, petitions, and demands that they may 

have between and among them and certain other released parties, as described below, including, 

but not limited to, any and all claims arising out of or in any way related to Claimant’s retention 

by or separation from Defendants.

NOW, THEREFORE, in consideration of the mutual promises made herein and the 

releases described below, and for other good and valuable consideration, the receipt and 

sufficiency of which is hereby acknowledged, the Parties hereby agree as follows:

COVENANTS

1. Consideration. Within fifteen (15) days after delivering a fully executed copy of 

this Agreement to Defendants’ legal counsel, Laurent Badoux, Buchalter, 16435 N. Scottsdale 

Road, Suite 440, Scottsdale, Arizona 85254 (“Defendants’ Counsel”), Defendants will pay 

Claimant the gross amount of Three Thousand Dollars and No Cents ($3,000.00), from which no 

deduction or withholding shall be taken (the “Settlement Payment”). Defendants will pay the 

Settlement Payment to Claimant via a single check made payable to “Rusing Lopez & Lizardi, 

Case 2:15-cv-02563-SMM Document 103-1 Filed 07/09/20 Page 2 of 8
Confidential

Page 2 of 7

41023039v2

P.L.L.C. Trust Account.” Defendants’ Counsel will deliver the Settlement Payment to 

Claimant’s legal counsel, Mick Rusing, Rusing Lopez & Lizardi, P.L.L.C., 6363 North Swan 

Road, Suite 151, Tucson, Arizona 85718 (“Claimant’s Counsel”), within fifteen (15) days after 

the Parties execute this Agreement; provided, however, that Claimant’s Counsel must hold the 

Settlement Payment in the firm’s IOLTA account pending the Court’s approval of this

Settlement Agreement and entering of an Order dismissing the Lawsuit. 

In the event that the Court does not approve the Settlement Agreement and/or dismiss the 

Lawsuit, Claimant’s Counsel must return the Settlement Payment to Defendants’ Counsel and 

this Settlement Agreement will be voidable at Defendants’ discretion.

The Parties agree that they will construe the consideration as settlement of contractual 

claims, irrespective of any allegations contained in the Complaint, and that the intent of the 

Parties should govern the classification of the Settlement Payment for any applicable tax 

purposes. 

As a condition of payment of the Settlement Payment, Claimant and Claimant’s Counsel

each will execute a Form W-9 and return the forms to Defendants’ Counsel. Defendants must

cause a Form 1099 to be issued to Claimant and Claimant’s Counsel reflecting the Settlement 

Payment. Claimant is solely responsible for the reporting of the Settlement Payment with the 

proper taxing authorities, and for payment of any taxes resulting from receipt thereof. 

Defendants assume and retain any responsibility for any tax considerations or obligations arising 

from the making of the Settlement Payment, and nothing herein constitutes an assumption of any 

responsibility therefor by Claimant, nor can be so construed.

2. Receipt of All Benefits. Claimant acknowledges and represents that, other than 

the consideration set forth in this Agreement, Defendants have paid or provided all salary, 

wages, contract payments, retainers, signing bonuses, retention bonuses, incentive compensation, 

accrued vacation/paid time off, premiums, leaves, reimbursable expenses, commissions, and any 

and all other benefits and compensation due to Claimant. Claimant warrants and represents that 

she is not entitled to payment of any amount other than as set forth in this Agreement. 

3. Release of Claims and Dismissal of Lawsuit. 

(a) Claimant agrees that the Settlement Payment represents settlement in full 

of all outstanding obligations owed to Claimant by Defendants, and by Defendants’ current and 

former owners, managers, officers, directors, employees, agents, investors, attorneys, 

accountants, shareholders, administrators, affiliates, benefit plans, plan administrators, insurers, 

trustees, affiliates, holdings, divisions, and subsidiaries, and predecessor and successor 

corporations and assigns (collectively, the “Defendant Releasees”). Claimant, on her own behalf 

and on behalf of her respective marital community (if any), heirs, family members, consulting 

companies, executors, agents, and assigns, hereby and forever releases the Defendant Releasees 

from, and agree not to sue concerning, or in any manner to institute, prosecute, or pursue any 

claim, complaint, charge, duty, obligation, demand, or cause of action relating to any matters of 

any kind, whether presently known or unknown, suspected or unsuspected, that Claimant may 

possess against any of the Defendant Releasees arising from any omissions, acts, facts, or 

Case 2:15-cv-02563-SMM Document 103-1 Filed 07/09/20 Page 3 of 8
Confidential

Page 3 of 7

41023039v2

damages that have occurred from the beginning of time through and including the Effective Date 

of this Agreement, including, without limitation:

(i) any and all claims relating to or arising from Claimant’s

contractual and/or employment relationships with the Defendant Releasees (or any of them) and 

the termination of those relationships; 

(ii) any and all claims for wrongful discharge of employment; 

termination in violation of public policy; discrimination; harassment; retaliation; breach of 

contract, both express and implied; breach of covenant of good faith and fair dealing, both 

express and implied; promissory estoppel; negligent or intentional infliction of emotional 

distress; fraud; negligent or intentional misrepresentation; negligent or intentional interference 

with contract or prospective economic advantage; unfair business practices; defamation; libel; 

slander; negligence; personal injury; assault; battery; invasion of privacy; false imprisonment; 

conversion; and disability benefits;

(iii) any and all claims for violation of any federal, state, or municipal 

statute, including, but not limited to, Title VII of the Civil Rights Act of 1964; the Civil Rights 

Act of 1991; the Rehabilitation Act of 1973; the Americans with Disabilities Act of 1990; the 

Genetic Information Non-Discrimination Act; Section 1981 of the Civil Rights Act of 1866; the 

Equal Pay Act; the Fair Labor Standards Act; the Fair Credit Reporting Act; the Employee 

Retirement Income Security Act of 1974; the Worker Adjustment and Retraining Notification 

Act; the Family and Medical Leave Act; the Sarbanes-Oxley Act of 2002; the Arizona Civil 

Rights Act; the Arizona Labor Code; and the Arizona Employment Protection Act. 

(iv) any and all claims for violation of the federal or any state 

constitution;

(v) any and all claims arising out of any other laws and regulations 

relating to employment or employment discrimination, compensation, or benefits; and

(vi) any and all claims for attorneys’ fees and costs.

(b) Defendants, on their own behalf and on behalf of their respective marital 

communities (if any), heirs, family members, consulting companies, executors, agents, and 

assigns, hereby and forever release Claimant and her assigns (the “Claimant Releasees”) from,

and agree not to sue concerning, or in any manner to institute, prosecute, or pursue any claim, 

complaint, charge, duty, obligation, demand, or cause of action relating to any matters of any 

kind, whether presently known or unknown, suspected or unsuspected, that Defendants may 

possess against any of the Claimant Releasees arising from any omissions, acts, facts, or 

damages that have occurred from the beginning of time through and including the Effective Date 

of this Agreement, including, without limitation:

(i) any and all claims relating to or arising from Defendants’ 

contractual and/or employment relationships with the Claimant Releasees (or any of them) and 

the termination of those relationships; 

Case 2:15-cv-02563-SMM Document 103-1 Filed 07/09/20 Page 4 of 8
Confidential

Page 4 of 7

41023039v2

(ii) any and all claims for breach of contract, both express and implied; 

breach of covenant of good faith and fair dealing, both express and implied; promissory estoppel; 

negligent or intentional infliction of emotional distress; fraud; negligent or intentional 

misrepresentation; negligent or intentional interference with contract or prospective economic 

advantage; unfair business practices; defamation; libel; slander; negligence; personal injury; 

assault; battery; invasion of privacy; false imprisonment; and conversion;

(iii) any and all claims for violation of the federal or any state 

constitution;

(iv) any and all claims arising out of any other laws and regulations 

relating to employment; and

(v) any and all claims for attorneys’ fees and costs.

(c) The Parties agree that the releases set forth in this Paragraph 3 shall be and 

remain in effect in all respects as a complete general release as to the matters released. These 

releases do not extend to any obligations incurred under this Agreement. These releases do not 

release claims that cannot be released as a matter of law, including, but not limited to, any claim 

for workers’ compensation benefits, Claimant’s right to file a charge with or participate in a 

charge by the Equal Employment Opportunity Commission, or any other local, state, or federal 

administrative body or government agency that is authorized to enforce or administer laws 

related to employment (with the understanding that any such filing or participation does not give 

Claimant the right to recover any monetary damages against the Defendant Releasees; 

Claimant’s release of claims herein bars her from recovering such monetary relief).

(d) The Parties shall jointly move for a complete Dismissal of the Lawsuit 

with prejudice and shall take such other and further necessary steps to effectuate the dismissal of 

the Lawsuit. 

4. No Pending or Future Lawsuits. 

(a) Claimant represents that she has no lawsuits, claims, or actions pending in 

her name, or on behalf of any other person or entity, against any of the Defendant Releasees 

except the Lawsuit. Claimant also represents that Claimant does not intend to bring any claims 

on her own behalf or on behalf of any other person or entity against any of the Defendant 

Releasees.

(b) Defendants represent that they have no lawsuits, claims, or actions 

pending in their or any of their names, or on behalf of any other person or entity, against any of 

the Claimant Releasees except the Counterclaim in the Lawsuit. Defendants also represent that 

Defendants do not intend to bring any claims on their own behalves or on behalf of any other 

person or entity against any of the Claimant Releasees.

5. Confidentiality. Claimant agrees to maintain in complete confidence the 

existence of this Agreement, the contents and terms of this Agreement, and the consideration for 

this Agreement (hereinafter collectively referred to as “Separation Information”). Except as 

required by law, Claimant may disclose Separation Information only to her respective immediate 

Case 2:15-cv-02563-SMM Document 103-1 Filed 07/09/20 Page 5 of 8
Confidential

Page 5 of 7

41023039v2

family members, the Court in any proceedings to enforce the terms of this Agreement, 

Claimant’s attorney(s), and Claimant’s accountants and professional tax advisors to the extent 

that they need to know the Separation Information in order to provide advice on tax treatment or 

to prepare tax returns, and must prevent disclosure of any Separation Information to all other 

third parties. Claimant agrees that she will not publicize, directly or indirectly, any Separation 

Information.

Claimant acknowledges and agrees that the confidentiality of the Separation Information 

is of the essence. Claimant warrants that she has not disclosed, orally or in writing, directly or 

indirectly, any of the Separation Information to any unauthorized party.

6. No Cooperation. Claimant agrees that she will not knowingly encourage, counsel, 

or assist any attorneys or their clients in the presentation or prosecution of any disputes, 

differences, grievances, claims, charges, or complaints by any third party against any of the 

Defendant Releasees, unless under a subpoena or other court order to do so. Claimant agrees

both to (a) immediately notify Defendants upon receipt of any such subpoena or court order and 

(b) furnish, within three (3) business days of its receipt, a copy of such subpoena or other court 

order to Defendants. If approached by anyone for counsel or assistance in the presentation or 

prosecution of any disputes, differences, grievances, claims, charges, or complaints against any 

of the Defendant Releasees, Claimant shall state no more than that they cannot provide counsel 

or assistance.

7. Non-Disparagement. Claimant agrees to refrain from any disparagement, 

defamation, libel, or slander of any of the Defendant Releasees. Defendants agree to refrain 

from any disparagement, defamation, libel, or slander of any of the Claimant Releasees.

8. No Admission of Liability. The Parties understand and acknowledge that this 

Agreement constitutes a compromise and settlement of any and all actual or potential disputed 

claims: (a) by Claimant and against the Defendant Releasees, individually and collectively, and 

(b) by Defendants and against the Claimant Releasees, individually and collectively. No action 

taken by the Parties hereto, either previously or in connection with this Agreement, will be 

deemed or construed to be: (a) an admission of the truth or falsity of any actual or potential 

claims, (b) an acknowledgment or admission by Defendants of any fault or liability whatsoever 

to Claimant or to any third party, or (c) an acknowledgment or admission by Claimant of any 

fault or liability whatsoever to Defendants or to any third party. 

9. Costs. Except as provided in Paragraph 1 hereinabove, the Parties bear their own 

costs, attorneys’ fees, and other fees incurred in connection with the preparation of this 

Agreement.

10. Authority. The Parties represent and warrant that the signatories below have the 

authority to act on behalf of the respective individuals and entities. Claimant represents and 

warrants that she has the capacity to act on her own behalf and on behalf of all who might claim 

through her to bind them to the terms and conditions of this Agreement. Each Party warrants and 

represents that there are no liens or claims of lien or assignments in law or equity or otherwise of 

or against any of the claims or causes of action released herein.

Case 2:15-cv-02563-SMM Document 103-1 Filed 07/09/20 Page 6 of 8
Confidential

Page 6 of 7

41023039v2

11. No Representations. The Parties represent that they have had an opportunity to 

consult with an attorney and have carefully read and understand the scope and effect of the 

provisions of this Agreement. The Parties have not relied upon any representations or statements 

made by any other Party that are not specifically set forth in this Agreement.

12. Severability. In the event that any provision or any portion of any provision 

hereof or any surviving agreement made a part hereof becomes or is declared by a court of 

competent jurisdiction or arbitrator to be illegal, unenforceable, or void, this Agreement will 

continue in full force and effect without said provision or portion of provision; provided, 

however, that if a court or arbitrator determines the releases in Paragraph 3 hereinabove to be

void, the Agreement, including, without limitation, Defendants’ obligations in Paragraph 1 

hereinabove, is voidable in Defendants’ sole discretion.

13. Attorneys’ Fees. In the event that any Party brings an action to enforce its rights 

under this Agreement, the prevailing Party will be entitled to recover its costs and expenses, 

including the costs of mediation, arbitration, litigation, court fees, and reasonable attorneys’ fees,

incurred in connection with such an action.

14. Entire Agreement. This Agreement represents the entire understanding between 

the Parties concerning the subject matter of this Agreement and Claimant’s relationship, if any, 

with Defendants, including any and all events leading thereto and associated therewith, and 

supersedes and replaces any and all prior agreements and understandings concerning the subject 

matter of this Agreement and Claimant’s relationship with Defendants. 

15. No Oral Modification. This Agreement may only be amended in a writing signed 

by each and every Party hereto.

16. Governing Law. This Agreement shall be governed by and construed and 

enforced in accordance with the laws of the State of Arizona without giving effect to the 

conflicts of law principles thereof.

17. Effective Date. This Agreement will become effective on the date on which the 

Court enters an Order approving this Agreement (the “Effective Date”).

18. Construction. Counsel for Defendants initially drafted this Agreement but only as 

a matter of convenience and Counsel for Claimant subsequently reviewed and modified this 

Agreement. Consequently, it is the intent of the Parties that the Agreement must not be 

construed for or against any Party for its role in drafting but shall be construed according to its 

plain meaning.

19. Counterparts. This Agreement may be executed in counterparts, via actual or esignature or by facsimile, and each counterpart, regardless of how executed, will have the same 

force and effect as an original and constitute an effective, binding agreement on the part of each 

of the undersigned.

20. Voluntary Execution of Agreement. The Parties understand and agree that they 

have executed this Agreement voluntarily, without any duress or undue influence on the part or 

Case 2:15-cv-02563-SMM Document 103-1 Filed 07/09/20 Page 7 of 8
Confidential

Page 7 of 7

41023039v2

behalf of any other Party or any third party, with the full intent of releasing all of their individual 

and collective claims as set forth in the releases in Paragraph 3. The Parties acknowledge that:

(a) They have each read this Agreement;

(b) They have been represented in the preparation, negotiation, and execution 

of this Agreement by legal counsel of their own choice;

(c) They understand the terms and consequences of this Agreement and of the 

releases it contains; and

(d) They are fully aware of the legal and binding effect of this Agreement.

IN WITNESS WHEREOF, the Parties have executed this Agreement on the respective 

dates set forth below.

JANE STRONG

Dated: ________________, 2020

STETSON DESERT PROJECT, LLC, d/b/a 

LÉ GIRLS CABARET

Dated: ________________, 2020

By:

Its:

CORY J. ANDERSON

Dated: ________________, 2020

CARY ANDERSON 

Dated: ________________, 2020

Case 2:15-cv-02563-SMM Document 103-1 Filed 07/09/20 Page 8 of 8