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equity, or otherwise from the beginning of time through the Preliminary Approval <br />Date that (1) were asserted in the Tenant Class Action and/or (2) could have been <br />brought in the Tenant Class Action. <br />3. All of Defendants' claims against the other Defendants and each of <br />their owners, members, shareholders, officers, employees, predecessors, and assigns <br />of any and every kind or nature, known or unknown, absolute or contingent, whether <br />in law, equity, or otherwise from the beginning of time through the Preliminary <br />Approval Date that (1) were asserted in the Tenant Class Action and/or (2) could have <br />been brought in the Tenant Class Action. <br />DD. "Released Parties" means each Person who is released from claims under this <br />Agreement, as specified in the definition of "Released Claims." <br />EE. "Releasing Parties" means each Party who is releasing claims under this <br />Agreement, as specified in the definition of "Released Claims." <br />FF. "Settlement" means the settlement set forth in this Settlement Agreement. <br />GG. "Settlement Administrator" means Lighthouse Management Group, an <br />independent, reputable, and competent professional -service company that will administer <br />Class Notice, administer the Settlement in accordance with this Settlement Agreement, and <br />engage in any other tasks directed by the Court. <br />HH. "Settlement Agreement" or "Agreement" means this Settlement Agreement, <br />including all exhibits and addenda thereto. <br />II. "Settlement Fund" means the cash fund paid by Defendants in the total amount of <br />$250,000.00, as described in Section III, Paragraph A. <br />JJ. "Tenant Class Action" means the civil action entitled Chandler et al v. QT <br />Property Management, LLC, Court No. 62 -CV -20-2646, Ramsey County Court, State of <br />