SETTLEMENT AGREEMENTSettlement Agreement • January 31st, 2023
Contract Type FiledJanuary 31st, 2023This Settlement Agreement, dated as of the last date of the signatures below (the “Settlement Agreement” or “Settlement”), is made and entered into by and among the following Settling Parties: (i) Simona Opris, Adrian Adam, Britney Richardson, Diptesh Patel and Payal Patel (collectively the “Representative Plaintiffs”), individually and on behalf of the Settlement Class Members (as defined below), by and through Kenneth J. Grunfeld of the law firm Golomb Spirt Grunfeld, P.C. and Kelly K. Iverson and Patrick D. Donathen of the law firm Lynch Carpenter, LLP (collectively, “Settlement Class Counsel” or “ Plaintiffs’ Counsel”); and (ii) Sincera Reproductive Medicine (“Sincera” or “Defendant”), for the benefit of all Released Parties (as defined herein), by and through the Defendant’s counsel of record, Mark S. Melodia, Paul Bond, Nipun J. Patel and Sophie L. Kletzien of Holland & Knight LLP (“Defense Counsel”). This Settlement Agreement is intended by the Settling Parties to fully, finally