Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 1 of 163 EXHIBIT 1
Case 4:25-cV-01116-YGR Document 73-2 Filed 07/10/26 Page 2 of 163
SETTLEMENT AGREEMENT AND RELEASE OF ALL CLAIMS
Andrew Ghali, Samierdin Ahmadzai, Trevor Bantley, Dylan Bota, Michael Bradanini, Tony Brown, Michael Camera, Sam Carter, Sean Dailey, Trisha Dibernardo, Lashon Earnest, Timmothy Emick, Scott Finn, Ryan Garrett, Daniel Grueneberg, Miles Higgins, Jonathan Irizarry, Metin Kanikaynar, Ethan Kochis, Jaymes Laughlin, Evan Look, Sean Maloney, Shane Mantor, Craig Martin, Kyle Means, Benjamin Moreno, Dylan Reeves, Jason Silva, Errol Thomas Simonitsch, Nicolas Stevens, Keith Stone, Rudy Suliven, Jarred Tomasini, Derek Trinidade, Zachary Wernke, Zachary White and Daniel Wuerthner, on behalf of themselves and all similarly situated individuals v. City of Hayward
Case No. 4:25-CV-01116-YGR
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
This document is subject to public disclosure.
This Settlement Agreement and General Release ("Agreement") is entered into between Defendant CITY OF HAYWARD and its past or present members of the City Council, elected officials, directors, employees, agents, predecessors, attorneys, divisions, departments, representatives, insurers, successors in interest and assigns, and all persons acting by, through, under or in concert with any of them (collectively, the "CITY"), on the one hand, and Plaintiffs ANDREW GHALI, SAMIERDIN
AHMADZAI, TREVOR BANTLEY, DYLAN BOTA, MICHAEL BRADANINI, TONY BROWN,
MICHAEL CAMERA, SAM CARTER, SEAN DAILEY, TRISHA DIBERNARDO, LASHON
EARNEST, TIMMOTHY EMICK, SCOTT FINN, RYAN GARRETT, DANIEL GRUENEBERG,
MILES HIGGINS, JONATHAN IRIZARRY, METIN KANIKAYNAR, ETHAN KOCHIS, JAYMES
LAUGHLIN, EVAN LOOK, SEAN MALONEY, SHANE MANTOR, CRAIG MARTIN, KYLE
MEANS, BENJAMIN MORENO, DYLAN REEVES, JASON SILVA, ERROL THOMAS
SIMONITSCH, NICOLAS STEVENS, KEITH STONE, RUDY SULIVEN, JARRED TOMASINI,
DEREK TRINIDADE, ZACHARY WERNKE, ZACHARY WHITE, AND DANIEL WUERTHNER, and all similarly situated individuals (collectively "PLAINTIFFS") on the other.
The CITY and PLAINTIFFS are collectively referred to as the "Parties" or individually as a "Party" with reference to the following:
RECITALS
A. WHEREAS, on February 3, 2025, PLAINTIFFS, Firefighters currently employed by the CITY, filed a civil complaint against the CITY, in the United States District Court for the Northern District of California, Case No. 4:25-CV-01116-YGR ("LAWSUIT'), alleging a violation of the Fair Labor Standards Act ("FLSA") and seeking damages for nonpayment of overtime based on the CITY'S alleged failure to pay PLAINTIFFS all overtime compensation eared.
B. WHEREAS, on May 15, 2025, Plaintiffs served the LAWSUIT on the CITY.
C. WHEREAS, Plaintiffs' Complaint alleges violations of the Fair Labor Standards Act (29 U.S.C. § 201, et seg.) ("FLSA") and seeks recovery of allegedly unpaid back overtime pay and 13155472 6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2| Filed 07/10/26 Page 3 of 163 liquidated damages under a three-year statute of limitations, as well as attorneys' fees and costs ("'Complaint"); and
D. WHEREAS, the Complaint alleges that the City owes back overtime pay to current and former non-exempt employees who received payments in lieu of health benefits ("cash-in-lieu"); and E. WHEREAS, the Complaint alleges that for the Firefighter Subclass, represented by current and former members of the International Association of Firefighters Local 1909, the City used an "hourly" methodology (29 C.F.R. § 778.110) instead of a "salary" methodology (29 C.F.R. § 778.113) to calculate overtime, despite their salaried status under the Memorandum of Understanding (MOU) and Salary Schedule, resulting in underpayment; and F. WHEREAS, by April 1, 2026, a total of 140 current or former City employees had joined the Action; and
G. WHEREAS, the Court entered an order conditionally certifying this matter as a collective action and approving a facilitated notice process, including directing that Defendant provide contact information for putative class members and that Plaintiffs' counsel administer notice; the Court ordered that, within thirty (30) calendar days, Defendant shall provide Plaintiffs' counsel the full names, last-known addresses, and non-work email addresses of all members of the Class, in an electronically manipulable format; and the Court further ordered that Plaintiffs' counsel shall administer the notification process and send notices by email or, if the employee does not have email, by mail to the employee's last known address, to all putative class members within thirty (30) days after receiving the list from Defendant; and
H. WHEREAS, Defendant provided the notice list on February 27, 2026; and I. WHEREAS, on March 20, 2026, the Parties filed a stipulation notifying the Court of their efforts to reach a settlement that would eliminate the need for notice by including the collective class in any approved recovery and requesting an extension of Plaintiffs' deadline to administer notice; and
J. WHEREAS, on March 23, 2026, the Court approved and ordered the extension of the deadline for Plaintiffs' counsel to administer the notification process and send notices to all putative class members by thirty (30) days; and
K. WHEREAS, the Parties reached a settlement that obviates the need to send notice because the City agreed to provide back payments to putative Plaintiffs in the Collective Class on the same terms as the joined Plaintiffs without requiring execution of a release of all claims; and L. WHEREAS, PLAINTIFFS' claims are in all respects controverted, and the applicability of the FLSA to the facts as alleged in the LAWSUIT, as well as the applicable level of compensation, and requests for damages is disputed.
M. WHEREAS, in an effort to resolve the issues raised in this LAWSUIT, and avoid the potential uncertainty, expense, and delay of litigation, the PARTIES have engaged in negotiations regarding PLAINTIFFS' FLSÁ claims. Throughout these negotiations, the PARTIES were and continue to be represented by counsel experienced in wage and hour, employment, and labor matters. 2 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 4 of 163 N. WHEREAS, on or about April 1, 2026, the Parties agreed to fully resolve all claims in this LAWSUIT for a certain settlement amount; and
O. WHEREAS, effective with the City's August 11, 2025 payroll, the City incorporated cash-in-lieu payments into its overtime calculation practices to meet its minimum FLSA obligations; and P. WHEREAS, the Parties agreed to amend the labor agreements governing the overtime pay of the Firefighter Subclass to pay FLSA overtime consistent with 29 C.F.R. section 113.778, effective the first full pay period after the Court's approval of the Ghali settlement; and Q. WHEREAS, the City denies any and all of the claims and allegations asserted by PLAINTIFFS in the LAWSUIT, but the City wishes to avoid the uncertainty of continued litigation and incurring additional litigation expenses.
The recitals set forth in this Agreement are true and correct and are hereby fully incorporated by reference into this Agreement. This Agreement affects claims and demands which are disputed, and by executing this Agreement, no Party admits or concedes any of the claims, including, but not limited to, whether PLAINTIFFS are entitled to overtime compensation, defenses, or allegations which were raised or could be raised by any other Party or any third party. Each Party expressly denies liability for any and all claims or demands. The PARTIES acknowledge that this is a compromise settlement of a disputed claim or claims. Moreover, neither this Agreement, nor any part of this Agreement, shall be construed to be, nor shall be, admissible in any proceeding as evidence of, or as an admission by, any party of any violation of law or any wrongdoing whatsoever. This document may be introduced in a proceeding to enforce the terms of the Agreement.
NOW THEREFORE, and in consideration for the promises contained herein and other good and valuable consideration, receipt of which is acknowledged by the execution of this Agreement, and to avoid unnecessary litigation, it is agreed by and between the PARTIES as follows:
SETTLEMENT TERMS
SETTLEMENT AMOUNT
Subject to the Court's approval of this Agreement, the City shall pay a total of $600,000.00 in this Action, and this amount shall include all of Plaintiffs' damages, attorneys' fees, and costs to settle the Action. The allocation of the Settlement Amount is described below. Although the Parties do not agree that there is liability regarding Plaintiffs' claims, for purposes of this Agreement, the settlement amount represents the agreed upon amount for all overtime compensation allegedly owed to Plaintiffs, arising from an alleged three-year statute of limitations ("RELEVANT STATUTORY PERIOD"') for recovery relief, and any and all other damages and/or relief recoverable in the Action, including liquidated damages, attorneys' fees and costs, for the full liability period alleged in the Action.
a) Payment to Plaintiffs: The total sum of $435,000.00 is allocated to Plaintiffs and the Putative Plaintiffs as set forth in Exhibit A. The City will issue payment to each Plaintiff and Putative Plaintiff no later than 45 days from the Effective Date of this Agreement.
3 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 5 of 163 The Parties agree that in lieu of Plaintiffs providing the Court approved notice to the Putative Plaintiffs, the City shall instead provide direct payments to all Putative Plaintiffs without requiring them to opt-in or sign releases. The payments to the Putative Plaintiffs were calculated on the same terms as the joined Plaintiffs and are included in Exhibit A.
The payments will be subject to tax withholdings as required by law. Plaintiffs acknowledge that the City has made no representations to them or their counsel regarding the tax consequences of any amounts received by them pursuant to this Agreement.
b) Disbursement of Payments. The City shall pay each individual Plaintift the amounts stated above. The amount of the settlement attributable to "Back Overtime Pay Amount" represents back pay and will be issued to each Plaintiff on an individual payroll check in the amount stated in the chart above. The sum attributable to back pay is subject to applicable employment tax withholdings. The back pay shall be included in each Plaintiff's 2026 W-2 as taxable wages. The sum attributable to the "Liquidated Damages Amount" will be directly issued to each Plaintiff in the amount stated in the chart above, for which the City will issue each Plaintiff an IRS Form 1099.
Plaintiffs acknowledge and agree that the City has made no representations to them or their counsel regarding the tax consequences of any amounts received by them pursuant to this Agreement. Plaintiffs agree to pay federal, state, and local taxes, if any, which are required by law to be paid with respect to this settlement. Plaintiffs further agree to indemnify and hold the City harmless from any claims, demands, deficiencies, levies, assessments, executions, judgments, or recoveries by any governmental entity against the City for any amounts claimed due from Plaintiffs related to the monies paid on account of this Agreement and for any costs, interest, expenses, fines, penalties, attorneys' fees or damages incurred or sustained by the City by reason of Plaintiffs' failure to pay such taxes. c) Service Award: A service award of $5,000 shall be paid to lead Plaintiff, Andrew shali, in recognition of his efforts on behalf of the Plaintiffs in prosecuting an ettling this LAWSUIT
d) Attorneys' Fees and Costs: The City shall issue payment in the amount of $160,000.00 to counsel for Plaintiffs, the law firm of Mastagni Holstedt, for Plaintiffs' attorneys' fees and costs. The $160,000.00 payment to Mastagni Holstedt is included in the total Settlement Amount of $600,000.00. The City will issue this payment no later than 45 davs from the Effective Date of this Agreement. Except as provided here, each Party will bear its own attorneys fees and costs.
e) PLAINTIFFS' signatures on this Agreement constitute an acknowledgment of the TOTAL PAYMENT to PLAINTIFFS, affirming the TOTAL PAYMENT is accepted as fair, just, and reasonable, and constitutes a full and complete payment in resolution of all 4 13155472 6 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 6 of 163 claims asserted in the LAWSUIT against the CITY for the RELEVANT STATUTORY PERIOD.
f) PLAINTIFFS acknowledge that all appropriate contributions based on any lost wages have been previously made and that no further contributions are required from the TOTAL SETTLEMENT AMOUNT. PLAINTIFFS further release and waive any and all claims related to pension contributions, retirement account contributions, benefit plan contributions, or benefit accruals of any kind that are based upon, arise from, or relate to the overtime compensation that is the subject matter of this LAWSUIT.
2. DISMISSAL OF LITIGATION AND PENDING ACTIONS
PLAINTIFFS will dismiss with prejudice the LAWSUIT and will withdraw or dismiss any other related complaint, claim, grievance, or charge seeking FLSA and/or MOU overtime compensation that PLAINTIFFS have filed against the CITY seeking FLSA and/or MOU overtime compensation occurring up to and including the Effective Date of this Agreement. This Agreement extends to any such complaint, claim, grievance, or charge filed in any state or federal court, with any administrative body, agency, board, commission, or other entity - within the City or external to the City - whatsoever. To accomplish the dismissal of the LAWSUIT, the Parties shall file a JOINT MOTION FOR APPROVAL of FLSA SETTLEMENT AND DISMISSAL OF ACTION WITH PREJUDICE ("JOINT MOTION"). If for any reason the Court declines to approve the JOINT MOTION, the Parties shall promptly meet and confer in a good faith effort to prepare a form of stipulation and order, or other similar decree, acceptable to the Court and consistent with the terms of this Agreement. Should the Court refuse to approve the terms of this Agreement, the Parties shall promptly meet and confer in a good faith effort to prepare a form of settlement agreement acceptable to the Court.
3. GENERAL RELEASE
Plaintiffs accept this Settlement, and understand that Plaintiffs' acceptance of this settlement constitutes a full and complete settlement of all claims for back wages against Defendant City, under any theory, that may exist or have existed up to and including the Effective Date of this Agreement, including all claims made in this lawsuit for unpaid wages, liquidated damages and attorneys' fees under the maximum statute of limitations, and Plaintiffs hereby fully, finally and completely release, waive and discharge Defendant City, and its officers, agents, employees, successors and assigns from any further claims for back wages under any legal theory, for any alleged underpayment relating to or arising from the claims raised in this Action occurring up to and including the Effective Date of this Agreement. Plaintiffs reserve the right to pursue any claims they might have for events occurring after the Effective Date of this Agreement.
All Parties to this settlement understand that this Release extends only to all grievances, disputes or claims of every nature and kind, known or unknown, suspected or unsuspected, arising from or attributable to claims related to or arising from this Action up to and including the Effective Date of this Agreement. The Parties understand that this release does not include claims relating to conduct or activity not relating to or arising from this Action or to any conduct or activity which occurs after the Effective Date of this Agreement. The Parties understand that this is a compromise 5 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 7 of 163 settlement of disputed claims, and that nothing herein shall be deemed or construed at any time or for any purpose as an admission of the merits of any claim or defense.
The Parties further acknowledge that any and all rights granted them under section 1542 if the California Civil Code are hereby expressly waived regarding Plaintiffs' claims relating t r arising from this Action up to and including the Effective Date of this Agreement, but not a to other claims. Section 1542 of the California Civil Code provides as follows:
A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS
THAT THE CREDITOR OR RELEASING PARTY DOES
NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER
FAVOR AT THE TIME OF EXECUTING THE RELEASE
AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE
MATERIALLY AFFECTED HIS OR HER SETTLEMENT
WITH THE DEBTOR OR RELEASED PARTY.
4. RELEASE OF CITY'S CLAIMS
In exchange for Plaintiffs' release of claims, the City releases any claim for attorney's fees and costs incurred in this proceeding against any Plaintiff.
KNOWLEDGE OF PARTIES
The Parties understand and agree to the settlement, this Agreement, and the terms and conditions contained herein, and enter into this Agreement knowingly and voluntarily. Plaintiffs have been advised that they have the right to seek legal advice with respect to this Agreement, including the release, have had the opportunity to consult with counsel, and have in fact consulted with counsel of their choice. The Parties have investigated the facts pertaining to the settlement and the Agreement and all matters pertaining thereto as deemed necessary. The Parties have relied upon their judgment, belief, knowledge, understanding, and expertise after having been afforded the opportunity to consult with their counsel concerning the legal effect of the settlement and its terms. By signing this document and the releases attached as Exhibit B, the Parties signify their full understanding, agreement, and acceptance of the Agreement.
ENTIRE AGREEMENT
This Agreement, Exhibit A, and the Acknowledgment and Release forms for each Plaintiff attached as Exhibit B, constitute the entire agreement between the Parties regarding this Action.
No other promise or inducement has been offered for this Agreement. Unless ordered otherwise by the Court, any amendments to this Agreement must be in writing, signed by duly authorized representatives of the City and Plaintiffs, and must state that the Parties intend to amend the Agreement.
DUTY TO ACT IN GOOD FAITH
The Parties shall act in good faith and use their reasonable good faith efforts after the execution of this Agreement to ensure that their respective obligations hereunder are fully and 6 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 8 of 163 punctually performed. The Parties shall promptly perform any further acts and execute and deliver any other documents or instruments that may be reasonably necessary to carry out the provisions of this Agreement. The Parties shall promptly meet and confer in good faith to address any issues that may arise impacting the execution, approval, and performance of this Agreement.
INTERPRETATION AND CONSTRUCTION
Any ambiguities or uncertainties herein shall be equally and fairly interpreted and construed without reference to the identity of the Party or Parties preparing this document or the documents referred to herein, on the understanding that the Parties participated equally in the negotiation and preparation of the Agreement and the documents referred to herein, or have had equal opportunity to do so. The headings used herein are for reference only and shall not affect the construction of this Agreement.
9. NO ADMISSION OF LIABILITY
This Agreement and compliance with this Agreement shall not in any way be construed as an admission by any Party of the truth of any allegations, or an admission of any unlawful acts or other liability whatsoever against each other or against any other person or entity. The Parties specifically disclaim any liability to, against each other, or against any other person or entity, on the part of themselves, any related person or any related predecessor entity or its or their agents, representatives or successors in interest an assigns. This Agreement cannot be used by any person to demonstrate any admission or liability or wrongdoing by any Party to this Agreement, and this Agreement cannot be used by any person to establish that he or she or it is a third party beneficiary of this Agreement.
10. WARRANTY OF NON-ASSIGNMENT. The Parties warrant that they have not assigned any of the claims or portions of the claims that are the subject of this Agreement.
11. TOTAL CONSIDERATION. In no event shall the CITY pay PLAINTIFFS and PLAINTIFFS' attorneys anything more than the TOTAL SETTLEMENT AMOUNT specified in Paragraph 1 (above). PLAINTIFFS will receive no other benefits, no other financial consideration from the CITY, or other consideration as a result of entering into and/or executing this Agreement.
12. NO PRIOR ASSIGNMENTS. PLAINTIFFS represent that PLAINTIFFS have not assigned or transferred, or purported to assign or transfer, to any person or entity, any claim or any portion thereof or interest therein against the CITY.
13. CONVENANT TO EFFECTUATE AGREEMENT. Each Party agrees to do all things and execute and deliver all documents necessary to fulfill and give effect to the provisions of this Agreement and to protect the respective rights of the Parties to this Agreement.
14. NO DURESS OR UNDUE INFLUENCE. The Parties represent and agree that they have carefuly read and uly anderstand a or the provision of thi parent and a any Party, entering into this Agreement
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15. CONSULTATION WITH COUNSEL. The Parties affirm that, prior to execution of this Agreement, they have consulted with their respective legal counsel/representatives concerning the terms and conditions set forth herein, and they understand the advice provided to them.
16. ENTIRE AGREEMENT. This Agreement contains all of the terms and conditions agreed pon by the Parties regarding the subject matter of this Agreement. Any prior agreements romises negotiations, or representations, either oral or written, relating to the subject matte of this Agreement, not expressly set forth in this Agreement, are of not force or effect.
17. INTERPRETATION. This Agreement has been jointly negotiated and drafted by counsel or Parties. The language in this Agreement shall be construed as a whole according to it 'air meaning and not strictly for or against any of the Parties
18. SEVERABILITY. In the event that any provision of this Agreement is declared to be illegal, invalid, unenforceable, and/or void by a court of competent jurisdiction, such provision shall be deemed to be severed and deleted from this Agreement, but this Agreement shall in all other respect remain unmodified and continue in force and effect.
19. EXECUTION OF COUNTERPARTS. This Agreement may be executed in one or more counterparts, each of which shall be deemed an original, and all of which together shall constitute one and the same instrument. A photocopy or facsimile transmission of the Agreement, including signatures, shall be deemed to constitute evidence of the Agreement having been executed.
20. ENFORCEABLE AND BINDING AGREEMENT. This Agreement is intended to be binding and enforceable and reflects the material terms of the final agreement between the parties to this dispute, and each of them, pursuant to California Evidence Code Section 1123 and Rule 402 of the Federal Rules of Evidence. This Agreement is admissible and subject to disclosure, despite any otherwise enforceable requirements of confidentiality, for the purpose of enforcing and interpreting that agreement or as required by law.
EFFECTIVE DATE. The Effective Date of this Agreement shall be the last date on which all Parties have signed this Agreement.
¡SIGNATURES ON NEXT PAGEI
/lI
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Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 10 of 163 IN WITNESS WHEREOF, the Parties hereto have executed this Settlement Agreement and General Release.
CITY OF HAYWARD
Dated: 04/02/2026 Jerniger Ott
Jennifer Ott, City Manager
CITY OF HAYWARD
THE SIGNATURES AND RELEASES OF EACH INDIVIDUAL PLAINTIFF ARE
CONTAINED ON SEPARATE SIGNATURE PAGES ATTACHED AS EXHIBIT B AND INCLUDED HEREIN BY THIS REFERENCE.
APPROVED AS TO FORM AND CONTENT:
Dated: 04102/2026 MASTAGNI HOLSTEDT, A.P.C.
By: David Mastagni (Apr 2, 2026 19:04:27 PDT)
David Mastagni, Esq.
Attorneys for Plaintiffs
Andrew Ghali, et al.
Dated: 04/03/2026 CITY OF HAYWARD
Michael Lawson
By: Ma * 3 2026 16 41:45 PO7)
Michael Lawson
City Attorney
CITY OF HAYWARD
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Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 11 of 163
EXHIBIT A
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 12 of 163 Net Settlement Allocations
Ghali et al. v. City of Hayward, Case No. 4:25-CV-01116-YGR *The damages formula used resulted in a "Total" damages allocation for each individual. That "Total" was divided evenly between backwages and liquidated damages. When an individual's damages "Total" ended in an odd number, back wages were rounded up and liquidated damages were rounded down to the nearest $0.01.
Liquidated Total
Name Back Wages Damages
AHMADZAI, SAMIERDIN $ 5,987.97 $ 5,987.96 $ 11,975.93
ALLEN, BRIEA 62.50 $ 62.50 $ 125.00
ANAYA, ABRAHAM 62.50 $ 62.50 $ 125.00
ARMSTRONG, NATHANIEL LOUIS $ 62.50 $ 62.50 $ 125.00
BAKER, TOM $ 62.50 $ 62.50 $ 125.00
BANTLEY, TREVOR $ 1,355.41 $ 1,355.40 $ 2,710.81
$ 62.50 $ 62.50 $ 125.00
BARALE, DAVID
BARBANO, MARTIN $ 441.80 $ 441.79 $ 883.59
BEALS, ANDREW $ 62.50 $ 62.50 $ 125.00
$ 329.69 $ 329.69 $ 659.38
BEAUCHAMP, COLE
BECKER, BRUCE $ 1,836.38 $ 1,836.38 3,672.76
BLACK, ANDREW $ 269.49 $ 269.49 $ 538.98
$ 1,427.72 $ 1,427.72 $ 2,855.44
BOTA, DYLAN
BRADANINI, MICHAEL $ 2,272.50 $ 2,272.50 $ 4,545.00
BRASSFIELD, ERIC $ 304.32 $ 304.31 $ 608.63
BRENNAN,JOE $ 62.50 $ 62.50 $ 125.00
BRICEÑO, MARCO $ 62.50 $ 62.50 $ 125.00
BROWN, MATTHEW $ 1,649.79 $ 1,649.78 3,299.57
BROWN, SPRING $ 206.19 $ 206.19 $ 412.38
BUCKINGHAM, MATT $ 810.05 $ 810.04 $ 1,620.09
BUENROSTRO,OMAR $ 62.50 $ 62.50 $ 125.00
CAMERA, MICHAEL $ 1,757.46 $ 1,757.46 $ 3,514.92
CARDWELL, CONNER $ 227.36 $ 227.35 $ 454.71
CARTER, SAM $ 218.07 $ 218.07 $ 436.14
CASTILLO, CHRIS $ 645.82 $ 645.81 $ 1,291.63
CLARKE, DANIEL $ 674.26 $ 674.25 $ 1,348.51
CONTE, ANTHONY $ 1,688.46 $ 1,688.45 $ 3,376.91
CRAIG, WILLIAM $ 220.42 $ 220.42 $ 440.84
CRAWFORD, JESSE $ 322.37 $ 322.37 $ 644.74
CRESPO, FRANK $ 1,470.46 $ 1,470.45 $ 2,940.91
CREW, BENJAMIN $ 1,102.43 $ 1,102.43 $ 2,204.86
CRIVELLO, TROY $ 1,722.04 $ 1,722.03 $ 3,444.07
DAGGETT, BENJAMIN 550.75 $ 550.74 $ 1,101.49
DAGGETT, BRIAN $ 1,127.26 $ 1,127.26 $ 2,254.52
DAILEY, SEAN $ 938.39 $ 938.38 $ 1,876.77
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 13 of 163 $ 105.52 105.52 $ 211.04
DARABIAN, SAUSAUN
DAVIS, CHEYENNE $ 219.32 219.31 $ 438.63
DAYTON, RYAN $ 158.58 $ 158.57 317.15
$ 488.13 488.12 $ 976.25
DEA, MICAH
DELGADO, LUCAS $ 532.67 532.66 $ 1,065.33
DIEBOLD, JONATHAN $ 2,164.69 $ 2,164.69 $ 4,329.38
DIMICK, JEFF $ 1,015.47 $ 1,015.46 $ 2,030.93
$ 693.83 $ 693.82 $ 1,387.65
DISNEY, MATT
DOLLARD, IAN $ 1,161.52 $ 1,161.52 $ 2,323.04
DOMINGUEZ, MICHAEL $ 62.50 $ 62.50 $ 125.00
DONG, JONATHAN $ 1,486.39 $ 1,486.39 $ 2,972.78
EARNEST, LASHON $ 4,257.19 $ 4,257.19 $ 8,514.38
ELIZARREY, BRIANNE $ 62.50 $ 62.50 $ 125.00
ELLWEIN, CLARISSA $ 255.00 $ 255.00 $ 510.00
EMICK, TIMMOTHY $ 2,784.80 $ 2,784.79 $ 5,569.59
ESTRADA, JOE $ 104.14 $ 104.14 $ 208.28
$ 183.64 $ 183.63 $ 367.27
FARINARO, STEVEN
$ 1,549.46 $ 1,549.46 $ 3,098.92
FERGUSON, DARREN
$ 2,703.33 $ 2,703.32 $ 5,406.65
FINN, SCOTT
$ 2,722.16 2,722.16 $ 5,444.32
FITZGERALD, CHRIS
$ 2,898.41 $ 2,898.41 5,796.82
FITZGERALD, WARREN
$ 682.44 $ 682.44 $ 1,364.88
FOSTER, TRAVIS
$ 1,247.47 $ 1,247.46 $ 2,494.93
FRANK, ROBERT
$ 185.77 $ 185.77 $ 371.54
FREDRICKSON, KRISTA
$ 4,849.55 $ 4,849.55 $ 9,699.10
GARRETT, RYAN
$ 1,212.36 $ 1,212.36 $ 2,424.72
GHALI, ANDREW
$ 888.16 $ 888.16 $ 1,776.32
GOINS, AARON
GOMEZ, LAURA $ 62.50 $ 62.50 $ 125.00
GONZALEZ,NATASHA $ 62.50 $ 62.50 $ 125.00
$ 1,364.53 $ 1,364.52 $ 2,729.05
GOTRO, MICHAEL
$ 62.50 $ 62.50 $ 125.00
GRAVES, ANA
GRUENEBERG, DANIEL $ 3,003.44 $ 3,003.44 $ 6,006.88
HALL, JOSEPH $ 843.96 $ 843.95 $ 1,687.91
HAME, RYAN $ 295.76 $ 295.75 $ 591.51
HIGGINS, MILES $ 1,752.19 $ 1,752.19 $ 3,504.38
HILDEBRAND, MICHAEL $ 3,656.72 $ 3,656.72 $ 7,313.44
HOBBS, JOSHUA $ 493.46 $ 493.45 $ 986.91
HUNTER,CHANTE $ 62.50 $ 62.50 $ 125.00
HUSSEY, LOGAN 464.80 $ 464.79 $ 929.59
IRIZARRY, JONATHAN $ 1,712.83 $ 1,712.82 $ 3,425.65
JOHNSTON, TIMOTHY $ 1,180.42 $ 1,180.41 $ 2,360.83
KAMENY, BRANDON $ 400.59 $ 400.59 $ 801.18
KANIKAYNAR, METIN $ 62.50 62.50 $ 125.00
KAZEMI, ANDREW $ 1,944.45 $ 1,944.44 $ 3,888.89
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 14 of 163 KEMP, GRANT $ 316.61 $ 316.60 $ 633.21
KLAUSING ,STEVEN $ 62.50 $ 62.50 $ 125.00
KNAUB, DAVID $ 1,354.39 $ 1,354.39 $ 2,708.78
KOCHIS, ETHAN $ 2,130.08 $ 2,130.08 $ 4,260.16
KULAS, CARA $ 202.47 $ 202.46 $ 404.93
LANSAC, GREGORY $ 1,334.99 $ 1,334.98 $ 2,669.97
LAUGHLIN, JAYMES $ 62.50 $ 62.50 $ 125.00
LEE, RYAN $ 4,591.88 $ 4,591.88 $ 9,183.76
LEONARD, JEFFREY $ 1,943.28 $ 1,943.28 3,886.56
LIVERMORE, JASON $ 987.71 $ 987.71 $ 1,975.42
LOOK, EVAN $ 2,168.68 $ 2,168.68 $ 4,337.36
LOPEZ, EDWARD $ 255.31 $ 255.31 $ 510.62
LORA, MATTHEW $ 2,245.21 $ 2,245.21 $ 4,490.42
LORDE, VERNELL $ 489.14 $ 489.14 $ 978.28
$ 690.82 $ 690.81 $ 1,381.63
MACIAS, CESAR
$ 1,450.81 $ 1,450.80 $ 2,901.61
MADDOX, AARON
$ 5,522.39 $ 5,522.39 $ 11,044.78
MALONEY, SEAN
MANTOR, SHANE $ 3,454.48 $ 3,454.48 $ 6,908.96
$ 1,019.52 $ 1,019.51 $ 2,039.03
MAR, ALAN
$ 62.50 $ 62.50 $ 125.00
MARPLES, NORMA
MARQUEZ, NICHOLAS $ 678.62 $ 678.61 1,357.23
MARTIN, CRAIG $ 4,766.37 $ 4,766.36 $ 9,532.73
MARTY, LANDON $ 903.94 $ 903.94 $ 1,807.88
$ 62.50 $ 62.50 $ 125.00
MASIS, CYNTHIA
MASSONE, MILES $ 62.50 $ 62.50 $ 125.00
MATTHEWS, JARED $ 816.99 $ 816.98 $ 1,633.97
MCCOMBE, RYAN $ 133.67 $ 133.66 $ 267.33
MEANS, KYLE $ 2,590.34 $ 2,590.34 $ 5,180.68
MELLO, CRISELDA $ 62.50 $ 62.50 125.00
$ 62.50 $ 62.50 $ 125.00
MENDES, LEAH
MENDONCA, MARC $ 561.87 $ 561.86
MOORE, MASON $ 957.27 $ 957.27 $ 1,914.54
MOOTHART, JOSHUA $ 617.71 $ 617.71 $ 1,235.42
MORENO, BENJAMIN $ 1,122.90 $ 1,122.89 $ 2,245.79
$ 380.61 $ 380.60 $ 761.21
MORROW, DONALD
NEWTON, JORDEN $ 2,752.12 $ 2,752.11 $ 5,504.23
$ 62.50 $ 62.50 $ 125.00
NICHELSON, DON
OCHOA, CRISTOFER $ 625.33 $ 625.32 $ 1,250.65
O'NEILL, TIMOTHY $ 2,779.62 $ 2,779.62 $ 5,559.24
OPDYCKE, TIM $ 1,100.77 $ 1,100.76 $ 2,201.53
OSIAS, RHAY $ 62.50 $ 62.50 $ 125.00
OTTOBONI, GINO $ 445.42 $ 445.42 $ 890.84
PHILLIPS-SOTKA, MARTINIQUE $ 78.46 $ 78.46 $ 156.92
PIRZAD, WAIS $ 62.50 $ 62.50 $ 125.00
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 15 of 163 $ 493.61 $ 493.61 $ 987.22
POLANCO, ANDRES
QUAST, BRANDON $ 884.21 $ 884.20 $ 1,768.41
$ 163.92 $ 163.91 $ 327.83
RADEV, SVETLIN
RAMOS, PAUL $ 62.50 $ 62.50 $ 125.00
REARDON, TRISHA $ 62.50 $ 62.50 $ 125.00
REEVES, DYLAN 8,890.56 $ 8,890.56 $ 17,781.12
RINES, RONALD 419.07 419.07 $ 838.14
$ 62.50 62.50 125.00
RODRIGUEZ, LORI
ROMANO, KEITH $ 507.74 507.73 $ 1,015.47
184.76 $ 184.76 $ 369.52
SAIZ, FRANK
SALAZAR, ANDREW 62.50 $ 62.50 $ 125.00
SANDOVAL, ANDRES $ 124.11 $ 124.11 $ 248.22
SHULL, AUSTIN $ 1,554.07 $ 1,554.07 $ 3,108.14
SILVA, JASON $ 3,042.81 $ 3,042.81 $ 6,085.62
$ 2,504.61 $ 2,504.60 $ 5,009.21
SILVA, JUSTIN
SIMONITSCH, ERROL $ 2,749.14 $ 2,749.13 $ 5,498.27
SPEED, AARON $ 3,667.47 $ 3,667.47 $ 7,334.94
$ 138.84 $ 138.83 $ 277.67
SPINI, NICK
$ 183.10 $ 183.09 $ 366.19
STEVENS, NICOLAS
834.58 $ 834.57 $ 1,669.15
STILWELL, JOSEPH
$ 392.25 $ 392.25 784.50
STONE, KEITH
$ 117.73 $ 117.73 $ 235.46
SULIVEN, RUDY
$ 2,800.93 $ 2,800.93 $ 5,601.86
SULLIVAN, PATRICK
$ 1,512.46 $ 1,512.46 $ 3,024.92
SUPEBEDIA, BRANDON
TOMASINI, JARRED $ 30,109.01 $ 30,109.01 $ 60,218.02
$ 2,779.95 $ 2,779.95 $ 5,559.90
TRINIDADE, DEREK
$ 268.32 $ 268.32 $ 536.64
TUMACDER, DOUG
VALENCIA, RAUL 435.43 $ 435.42 870.85
VANDEVEER, ERICK $ 6,320.66 $ 6,320.66 $ 12,641.32
VARGAS ,DIANE $ 62.50 $ 62.50 $ 125.00
$ 62.50 $ 62.50 $ 125.00
VELMONTE, ROMAN
VICKERS, DANNY $ 916.98 $ 916.97 $ 1,833.95
VIEIRA, LINDSEY $ 62.50 $ 62.50 $ 125.00
WEATHERLY, CLAYTON 877.60 $ 877.60 $ 1,755.20
WERNKE, ZACHARY $ 702.10 $ 702.10 $ 1,404.20
WESTFIELD, ANDREW $ 481.40 $ 481.40 $ 962.80
WHITE, ZACHARY $ 1,078.25 $ 1,078.25 $ 2,156.50
WUERTHNER, DANIEL $ 6,641.53 $ 6,641.52 $ 13,283.05
YOUNGBLOOD, DAVID $ 970.81 $ 970.80 $ 1,941.61
TOTAL $ 217,500.30 $ 217,499.70 $ 435,000.00
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 16 of 163
EXHIBIT B
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 17 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: than (Apr 2, 2026 19:21:12 POT)
Print Name: Andrew Ghali
04/02/2026
Dated:
10 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 18 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1. the undersigned, um a present or former employce of City of Hayward and a Plantiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Setilement Agreement and Release and Exhihits A - B. 1 understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settiement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that 1 will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintifis, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime clams against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. nd hereby completely release the City per the waiver of nights covered by this Selflemen Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andres Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penally of perjury that the foregning is true and correct.
Signature:
Samierdin Ahmadza,
Print Name:
4|6/26
Dated:
10 13159372011:020-004
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 19 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated I certify under penalty of perjury that the foregoing is true and correct.
Signature: Briea Allen
Print Name: Briea Allen
Dated: 4/10/26
10 13155472.6 TU020-094
Case 4:25-CV-UTT16-YGR Document 73-2 Filed 07/10/26 Page 20 of 163
SETTEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1. the undericoed, mar present ot lomer employse of Cly ne Haywart and a Plastin the cisc. 1 the undersigned, bonehy almowledge dier 1 nuderiand and agnee to the inma and conderives contamel in the Settlement Agement snu Releste aon Esnibis A - B / understand this my atomy Managhi Helprit, and repre unanyes have negoosica settlement with the City to malve my chitt in fis case have reviewed the isdividu? settlemen pasten arount that will musie set forth in Extem Arse Die Senterest Agreement and Malagni Holsted constives a Tail and coomlete serioment of all a FINLand MOU mustine clams aganst be Chryseled to the aton enter Chalien elainend Cate No. 4:25-c-01/10-XGR 1 scar PheA
ирову по совет я полатив восьм смог Lo ta Selcaen aeca and Kelead and leeby sampleled relice de Dily perine wider of right ened be the Sellephem Apocat and Rep lee to done with pledes i game fo the anion, dadere Teartile under penanty of estivy at he roning is trial comet sennature.
Prut Name
Dateil - 14-210
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 21 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correct. 112C
Signature:
Nate Alast-
Print Name:
" 0 \ 26
Dated:
10 Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 22 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Then B. Be
Signature:
Print Name: THOmAS B. BAKER
4/8/26
Dated:
10 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 23 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: _Trevor Bantley
Dated: _04/04/2026
10 13155472.6 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 24 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. riury that the foregoing is true and correct.
David Barále
Dated:
7-10-42
10 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 25 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attoreys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintifis, along with the S160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Wet Dated
Print Name: MARTiN BARBANO
Dated: 4|1026
10 13155472.6 TU020-094
Case 4:25-cV-01116-YGR Document 73-2 Filed 07/10/26 Page 26 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former omployce of City of Hayward and a Plaintiff in this case. L the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and Inderstand that my individual settlement payment amount, which is part of the City's tota ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No 1:25-Cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release nd hereby completely release the City per the waiver of rights covered by this Settlemen preement and Release, and agree to dismiss with prejudice, my claims in the action, Andre Ghall, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Andrew Beals
Print Name:
04/06/2026
Dated:
10 1113576 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 27 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hercy acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
Masagn Esca, on this a i and complete sto at al miy it ay to my loreys, claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: COLE BEAUCHAMP
Dated: 4-6-26
10 13155473.6 TL020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 28 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exbibits A - B opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Reuce Beek-
Signature:
Print Name: BRuce Becker
Dated: 4-4-2026
10 13155472.6 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 29 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Platiff in this case. I. the undersigned, hereby acknowledge that I understand and agree to the tents and conditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this casc. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's coral payinent of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attoneys.
Mastagni Holstedi, constitutes a full and complete settlement of all my ELSA and MOU overtine clains against the City related to the action, Andrew Ghali, el al. V. Ciry of Hayward, Case No 4:25-CV-01116-GR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, 1 voluntarily enter into this Settlement Agreement and Relcase and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Releasc, and agree to dismiss with prejudice, my claints in the action. Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
BLack
Print Name:
Dated: 4/13/26
10 13155472 6 T[020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 30 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1. the underaigned, ama present or fermor employce of City of Ingward and a f'laimiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree fo the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount. which is part of the City's total pay ment of 5i 10,000 to Piaintitis, along with the 5100.000 that the City will pay to my attorneys.
Mastayni Holstedt. constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. elle Gl. 1 accep! Des sellemend de fair and rensorable. Having beer afforded La opportunity to consult ivith counsel, 1 voluntarily enter into this Settlement Agreement and Release and hereby compierely release the City per the waiver of rights covered by this Sertiement Agreement and Release, and agree to dismiss with prejudice, my claims in the action. Andrew huit, et ai. r. ily oj iiuyward, Case ivo. 4:25-cx-üiiio-YGk.
I certify under penalty of perjury that the foregoing is true and correct.
Signature
Print Name: Dylan Bota
4-2-26
Dated:
10 13155472.6 TU020-094
Case 4:25-cV-01116-YGR Document 73-2 Filed 07/10/26 Page 31 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this casc. I, the undersigned, hereby acknowledge that I understand and agrce to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I undersiand that my attorneys, Mastagni Hoistedt, and representatives have negotiated ettlement with the City to resolve my claim in this case. 1 have reviewed the individual settlemen payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement anc understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the S160,000 that the City Will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-GR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
MICHAEL BRADANINI
Print Name:
04/06/26
Dated:
10 13155472 6 TU020-494
Case 4:25-cV-01115 73-2 Filed 07/10/26 Page 32/o1
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, an a present or former employee of City of ileyward and a Plaintiff in this case. 1 the undersigned, hereby acknowledge tbat 1 undersiand and agree to the tetons and conditions coniamed in this Settlement Agreement and Release and Exhibiis A - B.
T understand that my attorncys, Mastagni Holsted!, and representatives have negotiated payment of $440.000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstodi, constitutes a tall and complete settlemeni of all my FLSA and MOU overtine claims against the City related to the action, Andrew Ghali, er al. v. City of Hayward, Case No 1:35 cv-01116-YGR. I accept this settlement as fair and reasonable. Flaving been afforded the epportunity to consult with counsel, I voluntarily enter into this Settlement Agrecment and Reicess and hereby completely release the City per the waiver of righis covered by this Soulemen! Aereement and Reicasc, and agree to dismiss with prejudice, my ciaims in the action, Andrew Ghali ct al. v. Cin of Hayward, Case No. 4:25-c-01116-YGR.
I corrify under penalty of perjury that the foregoing is true and correct.
Signature:
ERIC BRASSHELT
Print Name:
414/2026
Dated:
13155472.6 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 33 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the S160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime opportunity to consult with counsel, 1 voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
josenh Brennon
Print Name:
4/13/26
Dated:
10 13155472.6 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 34 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employce of City of Hayward and a Plaintiff in this casc. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my altoreys, Mastagni Holstedt, and representatives have negotiated settiement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime payment of $440,000 to Plaintiffs, along with the S160,000 that the City will pay to my attorneys. claims against the Cily related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Marc Briceña
Dated: 04/07/2024
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name:
Dated:
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Hoistedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Spring Brow
11/4126
Dated:
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement I certify under penalty of perjury that the foregoing is true and correct.
Signature: Matt Buckingham
Print Name: Matt Buckingham
Dated: 04/04/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 1:25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Omar E. Buchrostro
Dated: 4/13/26
13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 39 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Mike CaMere
Signature:
Michael Camera
Print Name:
Dated: April 04, 2026
10 13155472.6 TU020-094
Docusign Envelope IDS 3F4923520-0319085YR420฿cument 73-2 Filed 07/10/26 Page 40 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
DocuSigned by:
Signature: Conner Cardwell
1196907A105F4D2..
Conner Cardwell
Print Name:
Dated: 4/8/2026
10 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 41 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement I certify under penalty of perjury that the foregoing is true and correct. 100
Signature:
Print Name: Sam Carter
Dated: 4/4/2026
10 13155472.6 TU020-094
Case 4:25-cV-01116-YGR Document 73-2 Filed 07/10/26 Page 42 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the verms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attoreys, Mastagni Holstedt, and representatives have negotialed setticment with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibil A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of S440,000 to Plaintifis, along with the S160,000 that the City will pay to my allomeys.
Mastagni Holsted, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, el al. v. Cir of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel. I voluntarily enter into this Sellement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release. and agree to dismiss with prejudice, my claims in the action. Andrew Ghali. et al. v: Cin of Haywand. Case No. 4:25-cx-01116-YGR I centify under penalty of perjury that the foregoing is true and correct. (shristopher Castille
Signature:
Christopher Castillo
Prini Name:
4/8/26
Dated:
10 Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 43 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total bayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. alty of perjury that the foregoing is true and correct.
Signature:
Print Name:
Daniel Clarke
Dated:
13155472 6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 44 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement I certify under penalty of perjury that the foregoing is true and correct.
Signature:
anthony conte
Print Name:
4/4/2026
Dated:
10 13155472 6 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 45 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: William Craig
Dated: 04/04/206
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlemen ayment amount that I will receive as set forth in Exhibit A to the Settlement Agreement an understand that my individual settlement payment amount, which is part of the City's total bayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime 4:25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Jesse Crawfora
Print Name:
Dated: 4/14 /26
10 13155472,6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 47 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement I certify under penalty of perjury that the foregoing is true and correct.
Signature: Frank Crespo
Print Name: Frank Crespo
Dated: 47/2026
10 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 48 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in his case. I, the undersigned, hereby acknowledge that I understand and agree to the terms an conditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated payment of S440,000 to Plaintiffs, along with the S160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No 4:25-cv-01116-YGR. 1 accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andren Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Byrh
Signature:
Print Name: Benjamin Crew
Dated: 4/1/2026
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Troy Crivello
Dated: 04/04/2026
10 13155472.6 TU020-094
Case 4:25-cV-01116-GR Document 73-2 Filed 07/10/26 Page 50 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case, 1, the undersigned, hereby acknowiedge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. 1 have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of S440,000 to Plaintiffs, along with the S160,000 that the City will pay to my attomeys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. 1 accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. y. City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Benjamin Daggett
Dated: 4/8/26
10 13155472.6 TUJ020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 51 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Brian Dagget
4/4/26
Dated:
13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 52 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total ayment ot 5440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. i penalty of perjury that the foregoing is true and correct.
Signature:
SEAN DALEY
Print Name:
4/14/26
Dated:
10 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 53 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Cheyenne Davis
04/08/2026
Dated:
10 13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 54 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I Will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Ryan Dayton
Dated: 4/8/26
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. 1 understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Mican Dea
Print Name:
Dated: 4/6/26
13155472.6 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 56 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1. the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that i understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that i will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, el al. v. City of Hayward, Case No. 4:25-Cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. Ciry of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Lucas Delgado
Dated: 4/8/26
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjudy that the foregoing is true and correct.
Signature:
John Diebold
Print Name:
04/03/2026
Dated:
10 13155472.6 TU020-094
Case 4:25-cv-03119 YEMERTER BEMENARKLERE 58 of 163
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
VellA
Signature:
Jeff Dimick
Print Name:
4/4/2026.
Dated:
10 Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 59 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and Managi Sisteit, on Plates af, lang wi thete set oment of the my wil and o doris, payment of $440,000 to Plaintiffs I certify under penalty of perjury that the foregoing is true and correct.
Signature: Matthew Disney
Print Name: Matthew Disney
Dated: 04/06/26
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
this casc. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in conditions contained in this Settlement Agreement and Release and Exhibits A - B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlement I understand that my attorneys. Mastagni Holstedt, and representatives have negotiated payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the S160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FISA and MOU overtime claims against the City related to the action, Andrew Ghali, er al. v: City of Hayward, Case No. 4:25-cv-01116-YGR. 1 accept this settlement as fair and reasonable. Having been afforded the nd hereby completely release the City per the waiver of rights covered by this Settlemen pportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Releas Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali. et al. v: City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correst.
Signaturc: MD
Print Name: Ian Dollard
Dated: 4-7-26
10 131554726 TUO20-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
MCHAEL Den moutz
Print Name:
Dated: 7/10/26
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
T. the undersigned, am a present or former employee of City of Hayward and a Plaintiff in »e to the terms ar
indian the undersigned, briety ackerlet ad lease and linoise. 1 • understand that my attorncys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have revicwed the individual settlement payment amoun that i will receive as sel forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's tot ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastagni Holstedi, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action. Andrew Ghali. et al. v. City af Hayward. Case No 4:25-cV-D1116-YGR. I accept this settlement as fair and rcasonable. Ilaving been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the Ciry per the waiver of rights covered by this Sculerent Agreement and Release, and agree to dismiss with prejudice, my claims in the action, adres Ghali, et al. v. City of Hayward. Case No. 4:25-cv-011 16-YGR.
I certify under penally of perjury that the foregoing is true and correct.
Signature:
JONATHAN Dowa
Print Namc:
4/420
Dated:
10 191554720100204144
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agrec to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Lasha T. Earnest
LA SHON T. EARNEST
Print Name:
04-08 - 2026
Dated:
10 131554726 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and settlement with the City to resolve my claim in this case. I have reviewed the individual settlement understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-GR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: CLARISSA ELLWEIN
Dated: 04-11 - 2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No.
4.25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Timmonty Emick
Print Name:
Dated: 04/04/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
Mastan of Sisted, coo Plains a f, lang coit pete set ement of the mity will and my torneys, payment of $440.000 to Plaintiffs Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Joe Estrada
Signature:
Joe Estrada
Print Name:
4-17-2026
Dated:
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and I certify under penalty of perjury that the foregoing is true and correct.
Surfaree
Signature:
Steven Farinaro
Print Name:
April 4, 2026
Dated:
13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 68 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I. the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I. the undersigned, hereby acknowledge that understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys. Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount. which is part of the City's total payment of St40.000 to Plaintiffs, along with the $160.000 that the City will pay to my attorneys.
Mastagni Holstedt. constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action. Andrew Ghali, et al. City of Hayward. Case No. 4:25-c-01116-YGR. I accept this settlement as fair and reasonable. Having heen afforded the opportunity to consult with counsel. I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release. and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, er al. v. Cin of Hayward. Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct. 2 Signature:
DARREN FERGUSON
Print Name:
Dated: 4.4-26
10 1a1864936101020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in his case. I, the undersigned, hereby acknowledge that I understand and agree to the terms an onditions contained in this Settlement Agreement and Relcase and Exhibits A - E payment of $440.000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, el al. v. City of Hayward. Case No 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward. Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Scor
Dated: 4/4/26
10 131554726 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct Signature:
Print Name: CHRISTOPHER FITZGERALD
Dated: 04/04/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1. the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the and hereby completely release the City per the waiver of rights covered by this Settlement opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v: City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
WARREN FIRGEROLO
Print Name:
4/7/26
Dated:
10 13155172 6 TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 72 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A -B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlement ayment amount that I will receive as set forth in Exhibit A to the Settlement Agreement anc understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: spain foren
Print Name: TRAVIS FOSTER
Dated: 4/10/26
13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
Masan: Ested oilies a land compete set on to let it and ry done, laims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No :25-CY-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded th opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct. 22 7K8
Signature:
Print Name: Robert Daniel Frank Tr
Dated: 04/08/2026
13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement anc understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
KRISTA FRENKELKION
Print Name:
4/23 2024
Dated:
13155472.G TU020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 75 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff ir his case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and nderstand that my individual settlement payment amount, which is part of the City's tot ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorney laims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No 1:25-CV-01116-GR. I accept this settlement as fair and reasonable. Having been afforded th and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andren Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
Signature:
RYAN GARRETT
Print Name:
4.4.26 Dated:
10 13155472.6 TU020-094
Case 4:25-cV-01116-YGR Document 73-2 Filed 07/10/26 Page 76 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I Will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total bayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Aaron Goins
Dated: _04/03/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No.
4.25-Cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Natate v Somals
Natasha Gonzalez
Print Name:
Dated: 417-26
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employce of City of Hayward and a Plaintiff in Ins case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this casc. I have revicwed the individual settlement payment amount that I will reccive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintifts. along with the $160.000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action. Andrew Ghali. et al. v. Cily of Hayward, Case No. 4:25-61-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice. my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Nike Ki Set
Signature:
MichaeL Kevin GoTRO
Print Name:
4-9-2026
Dated:
10 131554726 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
X0.
Signature:
Daniel Grueneberg
Print Name:
4/8/26
Dated:
13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v: City of Hayward, Case No 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, er al. v. City of Hayward, Case No. 4:25-cv-01 116-YGR.
I certify under penalty of perjury that the forgoing is true and correct.
Signature:
Print Name: Josoph T. Hall
4/8/26
Dated:
10 13155472 6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement anc understand that my individual settlement payment amount, which is part of the City's total claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the and hereby completely release the City per the waiver of rights covered by this Settlement Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Ryan Hamne
Print Name: Ryan Hamre
Dated: 4/5/2026
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlemen payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement an understand that my individual settlement payment amount, which is part of the City's total Myani Essed no Places lang wipile 1600 to at my it and my veners, Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
Signature:
Print Name: Miles Higgins
Dated: _04/08/2026
•
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INDIVIDUAL SIGNATURE PAGE
1. the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlemenr payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Hoistedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. y. City of Hayward, Case No 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable Having been afforded the opportunity to consult with counsel, 1 voluntarily enter into this Séttlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. r: City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: тіло польм
MIKE HE/DEBRAND
Print Name:
4/4/26
Dated
10 13195172611020-09
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this casc. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, 1 voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
JOSHUA HOBBS
Print Name:
Dated: 4/6/2026
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INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement anc understand that my individual settlement payment amount, which is part of the City's total Master FSted on this ful and complete set ement of al my is and o overine, claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury. that the foregoing is true and correct.
Signature:
Print Name: Chante Hunter
4-17-26
Dated:
10 13155472.6 TU020-094
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Aareement and Release, and agree to dismiss with prejudice, my claims in the action, Andren Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Logan Hussey.
Dated: _4/9/2026
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime nd hereby completely release the City per the waiver of rights covered by this Settlemen greement and Release, and agree to dismiss with prejudice, my claims in the action, Andre I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name:
Dated: 4/4/2026
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INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total Masagni fElted, o plates il and implete stone of the my is and a venes, claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of pertung that the foregoing is true and correct.
Signature:
Print Name: Timothy Johnston
Dated: 04/09/2026
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that i understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I cerify under penalty of perjury that the foregoing is true and correct.
Signature: Bess
Print Name: Brandon Krameny
Dated: 04/07/2026
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INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, 1 voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
METIN KANKAYNAR
Print Name:
4-8-26
Dated:
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff it this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I Will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Andrew Kazemi
Dated: 04/04/2026
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INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlemen payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total paymenio stadt, on Plain a, lang cith the stileont of the my wil and My overney e claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Grant Kemp
Dated: 04/08/2026.
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in conditions contained in this Settlement Agreement and Release and Exhibits A - B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlement I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of 5440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Steven Klausing
Dated: 41-12 - 26
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INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated Angemeny and Relay, an ege climes we are i ins covered by this suintren Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: DIN
Print Name: David J Knaub
Dated: 4/42026
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INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew I certify under penalty of perjury that the foregoing is true and correct. -
Signature:
Print Name: Ethan Kochis
Dated: 4/4/26
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INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintifis, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt. constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v: City of Hayward. Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the pportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Releas nd hereby completely release the City per the waiver of rights covered by this Settlemen Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v: Citv of Hayward. Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Gregory Lansac
Dated: 04/04/2026
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: for
Print Name: Jaymes D Laughlin
Dated: 4/14/2026
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. ayment amount that I will receive as set forth in Exhibit A to the Settlement Agreement an inderstand that my individual settlement payment amount, which is part of the City's tota payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Ryan Lee
Dated: 4/11/26
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INDIVIDUAL SIGNATURE PAGE
his case he tadesigned hereby a knowedge that endead and gad and pried conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of S440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No 4:25-cv-01116-YGR. I accept this settlement as fair and rcasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Aff towne
Signature:
Print Name: JEFF LEONARO
4-4-2026
Dated:
10 18547 3474
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in Ils case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms an onditions contained in this Settlement Agreement and Release and Exhibits A - E I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that i will receive as set forth in Exhibit A to the Settlement Agreement and opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
Signature:
Jason Livermore
Print Name:
Dated: 4/5/26
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1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms anc conditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andre Thali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Evan Look
Dated: 414/26
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual scttlement payment amount, which is part of the City's total ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Adany Lopy
Print Name: ERWARD LOPEZ
4/20\26
Dated:
10 13155472.6 TU020-094
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Matthew Lora
Print Name:
Dated: 4/5/2026
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1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in his case. I, the undersigned, hereby acknowledge that I understand and agree to the terms an onditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Aaron Maddox
Dated: 04/04/2026
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INDIVIDUAL SIGNATURE PAGE
-, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Sean Maloney
Dated: 4/4/2026
10 13155472 6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I Will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify u alty of perjury that the foregoing is true and correct.
Signature:
ShaRE Mantor
Print Name:
4|4120
Dated:
10 131554726 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in his case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. fastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim laims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case N 1:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Alan Mar
Dated: 4/4/20
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1. the undersigned, am a present or former employee of City of Hayward and a Plaintif in this case 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's totai payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related 10 the action, Andrew Ghali, el al. v. City of Hayward, Case No 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, er al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Nicholas Marquaz
Dated 4/4/2026
10 13155472617;020-íy›4
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Hoistedt, and representatives have negotiated Paymen of steal 010 Plaies f, l ang implete setteen at all my wil and M overine claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-Cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Craig Martin.
Dated: 04/04/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Scttlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the S160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLA and MOU overtime claims against the City related to the action. Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. 1 accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andren Ghali, et al. v. City of Hayward, Case No. 4:25-cv-011 16-YGR. 1 certify under penalty of perjury that the foregoing is true and correct.
Signature:
Landon Marty
Print Name:
04/4/2026
Dated:
Case 4:25-Cv-01116-YGR Document 73-2 Filed 07/10/26 Page 111 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlemen payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement an paymen of steal, coo Flies af, lang i ice stone at alt my wil and o overie, opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Miles Massone
Dated: _04/10/26
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, an a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Relcase and Exhibits A - B.
I understand that my attorneys, Mastagni Holsted, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Huyward, Case No. 4:25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Jael Matt
Jared Matthews
Print Name:
Dated: 4/4/26
10 131S5472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attoreys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and Mastagni Holstedi, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No.
1.25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Ryu Malanbe
Print Name: Ryan M'Combe
Dated: 04/08/2026
10 . 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Kyle Means
Dated: 04/07/2026
10 131554726 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total I certify under penalty of perjury that the foregoing is true and correct.
Me Mandin
Signature:
Marc Mendonca
Print Name:
04/04/2026
Dated:
10 13155472_6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated ettlement with the City to resolve my claim in this case. I have reviewed the individual settlemen ayment amount that I will receive as set forth in Exhibit A to the Settlement Agreement an understand that my individual settlement payment amount, which is part of the City's total ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorney lastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Mason Moore
Print Name:
4/4/26
Dated:
10 13155472 6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in his case. I, the undersigned, hereby acknowledge that I understand and agree to the terms an conditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime 4:25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the pportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlemen Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct. twit
Signature:
Print Name: Joshua Moothart
Dated: 04/04/26
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total paymen of tedio to lie it lang win ice 6400 a l my is and Mol overine, claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
BA
Signature:
Print Name: Benjamin Moreno
Dated: 4/4/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and n Plaintiff in this case. I, the undersigned, hereby acknowledge that i understand and agree to the terms and conditions contained in this Settlement Agrecment and Release and Exhibits A - B.
I understand that my attoreys, Mostagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that 1 will receive as sct forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of S440,000 to Plaintiffs, along with the S160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. 1 accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, er al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
Signature:
Donald Morrow
Print Name:
Dated: 4.16 • 2026
10 13135472 6 TL020-091
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that i understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury That the foregoing is true and correct.
Signature: fenders
Print Name: JORDEN NEWTON
Dated: 04.04. 2026
10 131554726 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated Masan sta, constitues a land compe 86l0 al my A an oy orgy , claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Con het
Signature:
DON NICAELSON
Print Name:
Dated: 4 16 26
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated ettlement with the City to resolve my claim in this case. I have reviewed the individual settlemer ayment amount that 1 Will receive as set forth in Exhibit A to the Settlement Agreement an understand that my individual settlement payment amount, which is part of the City's total paymen of sued, o Places at lang imple steen of the my us and a verine claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
GisOln
Signature:
Print Name: Cristofer Francis Ochoa
Dated: April 6th, 2026
10 131554726 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total paymen of stato to Plains if, lang complete stil on of al my it any lovence, claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-Cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew I certify under penalty of perjury that the foregoing is true and correct.
ONLi
Signature:
Print Name: Tim O'Neill
Dated: 4/4/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total paymen of sisted, no Plains lang wil ite seterent of the my wil and roy loreye, claims against the Cily related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Relcase, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Tin OPpycko
4.10-26
Dated:
10 13155472610020094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 125 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I. the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim claims against the City related to the action, Andrew Ghali, el al. v. City of Hayward, Case No 1:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Pray, A. Oki ju.
Print Name: Rhay A. Osias Jr.
Dated: 4/21/2026
13155472 6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorney lastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew gojng is true and, correct.
Signature:
Print Name: Gino Ottoboni
Dated: April 8th. 2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total paymenio strai on Plain a lang complete seriener of the may vil and a rene claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: _Wais Pirzad
Dated: 04/14/2026
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: ASDRES POLANCO
Dated: 4) 7/26
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: BRANDON QUAS
Dated: 4/9/26
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1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. 1 understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-Cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Faul Rawe
Signature:
Print Name: Paul Ramos
Dated: 04/08/26
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that 1 understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. 1 certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: TRisha heardon
Dated: 4-8-26
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INDIVIDUAL SIGNATURE PAGE
I. the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. 1 understand that my attoreys, Mastagni Holstedt, and representatives have negotiatec settlement with the City to resolve my claim in this case. I have reviewed the individual settlemen Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
DYLAN REEVES
Print Name:
4/1/2026
Dated:
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms anc onditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correct.
Ron RIn
Print Name:
07ÄPR2026
Dated:
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Torteuquen
LORI V RODRIGUEZ
Print Name:
Dated: 04/20/2024
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions containcd in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holsted!, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that i will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of S440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attomeys, Mastagni Holstedt, constitutes a full and complete scttlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-Cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, 1 voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Roleasc, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is truc and correct.
Signature: А т
Let RomANO
Print Name:
Dated: 4/4/24
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: It sag
Print Name: Frank Saiz
Dated: 4/6 / 26
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total Masagni ESsed, on fitics a til and compit stice of alt my i4 and l ring, claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
On n
Signature:
Print Name: Andres Sandoval
Dated: 04/08/2026
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INDIVIDUAL SIGNATURE PAGE
his case tense else one at yod candlyard and permitin
conditions contained in this Settlement Agreement and Release and Exhibits A - E I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Austin Shull
Dated: 04/04/26
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total Paymeni Fosted or Plain a land i le selector the my roll and a venere claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Jason Silva
Dated: 4/4/2026
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that i will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total bayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Mastani Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andren Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correct.
Signature:
JUSTIN SILVA
Print Name:
Dated: 1/4/2026
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintift in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total Mystani Fosted, no fires a lan complete set one of him will and are, claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-ev-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: ERROL THOMAS SIMONITSCH
Dated: APRIL 6, 2026
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that i understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward. Case No. 4:25-cv-01116-YGR. 1 accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Actan Speed
Dated: 4/13/26
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INDIVIDUAL SIGNATURE PAGE
I. the undersigned, am a present or former employee of City of Hayward and a Plaintiff in his casc. 1, the undersigned, hereby acknowledge that I understand and agree to the terms an conditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of S440.000 to Plaintiffs, along with the S160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtinie claums against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-C-01116-YGR. I accept this settlement as fair and reasonable. Having heen afforded the opportunity to consult with counsel. I voluntarily enter into this Settlement Agreement and Relcase and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v: City of Hayward. Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Nick Spini
Dated: 04/09/2026
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INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in his case. I, the undersigned, hereby acknowledge that I understand and agree to the terms an onditions contained in this Settlement Agreement and Release and Exhibits A - E I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and settlement with the City to resolve my claim in this case. I have reviewed the individual settlemen understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Nicolas Stevens
Dated: 10APR2G
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INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorney lastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim Andrew Ghali, et al. v. City of Hayward, Case No.
1-35- 0116 heR. related to th actiment as feir and reasonable. Hag tea attored the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and que sue mell
Signature:
Joe Stilwell
Print Name:
4/13/2026
Dated:
10 13155472 6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440.000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Hoistedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. Taccept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action. Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Keith Stone
Print Name:
Dated: 1. 8.2026
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Rudy Sil.
Signature:
RUDY SULIVEN
Print Name:
04-08 - 2026
Dated:
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorney:
lastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtim claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR I certify under penalty of perjury that the foregoing is true and correct.
Signature: Pativel M. Sli
Print Name: Patrick M. Sullivan
Dated: 8 Apr 2026
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. ettlement with the City to resolve my claim in this case. I have reviewed the individual settlemen ayment amount that I will receive as set forth in Exhibit A to the Settlement Agreement an understand that my individual settlement payment amount, which is part of the City's total Magni steal, on taies at alang womplete 16l onent of at my wil and ol overine claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Brandon Supebedia.
Dated: 04/08/2026
13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Jarred Tomasin.
Print Name:
4-6-26
Dated:
10 13133472.6 TU020-054
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Case 4:25-cV-01118 EFFLEMENPAZREEMEN7ANS REeLASt of 163
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andren Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. under penalty of perjury that the foregoing is true and correct.
Signature:
Derek Trinidade
Print Name:
4/4/26
Dated: -
10 Case 4:25-cV-01116-YGR Document 73-2 Filed 07/10/26 Page 152 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, 1 voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Doug Tumacder
Print Name:
4/14/26
Dated:
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 153 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree 1o the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. 1 understand that my attorneys, Mastagni Holstedt, and representatives have negoliated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay 1o my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and corect.
Signature:
Print Name:
46 2026
Dated:
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1. the undersigned. am a present or former employee of City of Hayward and a Plaintiff in this case. 1, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys. Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160.000 that the City will pay to my attorneys.
Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward. Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
ErickA Vandereer
Print Name:
Dated: 04-06-2026
10 13155472 6 10020-094
Case 4:25-CV-01116-YGR Document 73-2 Filed 07/10/26 Page 155 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Ilayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
Agreement and Relcasc, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Tame a Nager
Print Name: Diane L. Vargas
4/20/26
Dated:
13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 156 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true/and correct.
Dent
Signature:
He m
Print Name:
2470120
Dated:
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 157 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
T certify under penalty of perjury that the foregoing is true and correct. 1LD-
Signature:
Danny Vickers
Print Name:
Dated:
04/11/26
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-CV-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release greement and Kelease, a
Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Zaff
Print Name: Zachary Wernke
Dated: 04/04/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. understand that my individual settlement payment amount, which is part of the City's tota ayment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature: Of wis.
Annrew Westhers
Print Name:
Dated: 4/6/220
13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B. settlement with the City to resolve my claim in this case. I have reviewed the individual settlement ayment amount that I will receive as set forth in Exhibit A to the Settlement Agreement anc Masai staci, copies a land in it to to the miy wil and ry abortys, I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Clayton R Weatherly
Dated: 04/04/26
13155472.6 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 161 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
I, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in this case. I, the undersigned, hereby acknowledge that I understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Zachary White
Dated: 04/04/2026
10 13155472.6 TU020-094
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SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1, the undersigned, am a present or former employee of City of Hayward and a Plaintiff in his case. I, the undersigned, hereby acknowledge that I understand and agree to the terms an conditions contained in this Settlement Agreement and Release and Exhibits A - B I understand that my attorneys, Mastagni Holstedt, and representatives have negotiated settlement with the City to resolve my claim in this case. I have reviewed the individual settlement payment amount that I will receive as set forth in Exhibit A to the Settlement Agreement and understand that my individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attorneys, Mastagni Holstedt, constitutes a full and complete settlement of all my FLSA and MOU overtime claims against the City related to the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR. I accept this settlement as fair and reasonable. Having been afforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Release, and agree to dismiss with prejudice, my claims in the action, Andrew Ghali, et al. v. City of Hayward, Case No. 4:25-cv-01116-YGR.
I certify under penalty of perjury that the foregoing is true and correct.
Signature:
Print Name: Daniel Wuerthner
Dated: 4/4/2026.
131554726 TU020-094
Case 4:25-cv-01116-YGR Document 73-2 Filed 07/10/26 Page 163 of 163
SETTLEMENT AGREEMENT AND RELEASE
INDIVIDUAL SIGNATURE PAGE
1. the undersigned, am a present or former employee of City of Hayward and a PlaintifY in this case. I. the undersigned, hereby acknowledge that 1 understand and agree to the terms and conditions contained in this Settlement Agreement and Release and Exhibits A - B.
I understand that my attorneys, Mastagni Holstedl, and representatives have negotiated stillement with the City to resolve my claim in this case. I have reviewed the individual nettlement payment amouns that 1 will receive its act forth in Exhibit A to the Sculement Agreement and understand that my Individual settlement payment amount, which is part of the City's total payment of $440,000 to Plaintiffs, along with the $160,000 that the City will pay to my attomeys, Mastagni Holstede, constitutes a full and complete settlement of all my FLA and MOU overtime clams against the City related to the action. Andrew Ghali, et al. v. City of Hayward. Case No. 4:25-cy-DILiG YGR. I accept this settlement as fair and reasonable. Having been ufforded the opportunity to consult with counsel, I voluntarily enter into this Settlement Agreement and Release and hereby completely release the City per the waiver of rights covered by this Settlement Agreement and Releasc, and agree to dismiss with prejudice, my claims in the action, Andrew Ghalt. ot al. v. City of Harvard, Case No. 4:25cv-01116-YGR.
I certify under penalty of perjury thar the foregoing is tie and correct.
Signature:
Print Narc:
David Youngblood
Dated:
4-6-26
10 ANA (101a04