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Settlement Agreement

Farrell v. Bank of America, United States Court of Appeals for the Ninth Circuit Appeal No. 17-55847 United States District Court for the Southern District of California Case No. 3:16-CV-00492-L-WVG Settlement and Release Agreement Case 3:16-cv-00492-L-WVG Document 69-2 Filed 10/31/17 Page 2 of 73 1 This Settlement and Release Agreement ( Agreement ) dated as of October 30, 2017 is entered into by Plaintiffs Joanne Farrell, Ronald Dinkins, Larice Addamo, and Tia Little ( Plaintiffs ) on behalf of the Settlement class defined herein, and Bank of America, ( BANA ).

1.30 “Settlement” means the settlement of the Action by the Parties and the terms thereof contemplated by this Agreement. 1.31 “Settlement Amount” means Sixty-Six Million Six-Hundred Thousand Dollars ($66,600,000.00). 1.32 “Settlement Class” has the meaning ascribed to …

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