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This excerpt taken from the ALL 10-Q filed Nov 1, 2005. inter alia,
the allegations that the Class Members have suffered damage; that Allstate
mis-classified any Class Members as exempt employees; that Allstate failed
to provide any Class Members Breaks to which they were entitled; that
Allstate failed to pay any Class Members waiting time penalties and/or any
other penalties to which they claim to be entitled; that Allstate unlawfully
converted wages due Class Members; that Allstate engaged in any unlawful,
unfair or fraudulent business practices; that Allstate engaged in any wrongful
conduct as alleged in the Class Complaint; or that any Class Members
were harmed by any conduct alleged in, or that
Class Action Settlement Agreement Page 2
could have been alleged in, the Class Complaint. Neither this Agreement, nor any document referred to or contemplated herein, nor any action taken to carry out this Agreement, is, may be construed as, or may be used as an admission, concession or indication by or against Allstate of any fault, wrongdoing or liability whatsoever.
O. It is the intention of the parties to this Agreement to settle and dispose of, fully and completely, any and all claims, demands and causes of action set forth in the Class Complaint as described hereafter and any related claims, as between the Plaintiff Class and Defendant, as more fully set forth in paragraphs 15 through 18 of this Agreement.
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