Employee will not file, or become a plaintiff or claimant of any kind, in any lawsuit in court or in any arbitration proceeding against the Company (or any of the other Released Parties) for, or based on, any Waived and Released Claim. This includes, without limitation, Employee’s promise and agreement hereby not to become a named or opt-in plaintiff, class or collective action member or other claimant in any class action, collective action, representative action or other consolidated action in court or any arbitration proceeding for, or based on, any Waived and Released Claim, and to take all steps necessary to opt out of any such action. -David Scharf Separation Agreement (2017)
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