Blackmon - Settlement Agreement (Executed for Plaintiffs)

Case 5:20-cv-00988-JKP-ESC Document 65-3 Filed 01/21/22 Page 1 of 75. EXHIBIT 1. Case 5:20-cv-00988-JKP-ESC Document 65-3 Filed 01/21/22 Page 2 of 75. IN THE UNITED STATES DISTRICT COURT. FOR THE WESTERN DISTRICT OF TEXAS. SAN ANTONIO DIVISION. JAMES R. Blackmon , et al., : individually and on behalf of all others : similarly situated, : : Plaintiffs, : Civil Action No. 5:20-CV-00988-JKP-ESC. : v. : : ZACHRY HOLDINGS, INC., et al., : : Defendants. : : CLASS ACTION Settlement Agreement . This Class Action Settlement Agreement (the Settlement Agreement ) is entered into between and among the Class Representatives, all Class Members, and the Defendants. NOW, THEREFORE, without any admission or concession on the part of the Class Representatives of any lack of merit of the Class Action whatsoever, and without any admission or concession on the part of Defendants as to the merits of the allegations or claims asserted in the Class Action, it is hereby STIPULATED AND AGREED, by and among the Settling Parties to this Settlement Agreement , through their respective attorneys, subject to approval of the Court pursuant to Federal Rule of Civil Procedure 23(e), in consideration of the benefits flowing to the Settling Parties hereto from the Settlement Agreement , that all Released Claims as against th

Fiduciary, not to exceed $25,000; and (f) all fees, expenses, and costs associated with providing CAFA Notices. Excluded from Administrative Expenses are Defendants’ internal expenses and the Settling Parties’ respective legal fees and expenses. Administrative Expenses shall be paid from the Gross Settlement Amount. 1.3.

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