ContractExhibit 1 • January 13th, 2024
Contract Type FiledJanuary 13th, 2024This Settlement Agreement, dated as of the Effective Date, is made and entered into by and among the following Settling Parties (defined below): (i) Kurt Phillips, Michael Manson, Thomas Graham, and Austin Kohl (“Class Representatives”), individually and on behalf of the Settlement Class (defined below), by and through their counsel of record, Terence R. Coates of Markovits, Stock & DeMarco, LLC (“Proposed Class Counsel”) on the one hand; and (ii) Bay Bridge Administrators, LLC (“Bay Bridge” or “Defendant”), by and through its counsel of record, Timothy A. Butler and Christopher S. Dodrill of Greenberg Traurig, LLP (“Defendant’s Counsel”) on the other hand. This Settlement Agreement is subject to Court approval and is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Litigation (defined below) and Released Claims (defined below), upon and subject to the terms and conditions herein.