CLASS ACTION SETTLEMENT AGREEMENTClass Action Settlement Agreement • August 22nd, 2024
Contract Type FiledAugust 22nd, 2024This Settlement Agreement, dated as of the Effective Date, is made and entered into by and among the following Settling Parties (defined below): (i) Carla Tracy, Darryl Bowsky, and Deborah Harrington (“Class Representatives”), individually and on behalf of the Settlement Class (defined below), by and through their counsel of record, Bryan L. Bleichner of Chestnut Cambronne PA, and Terence R. Coates of Markovits, Stock & DeMarco, LLC (“Proposed Class Counsel”) on the one hand; and (ii) Elekta, Inc. (“Elekta”) and Northwestern Memorial Healthcare (“NMH”) (collectively, “Defendants”), by and through their counsel of record, Gregory T. Parks and Kristin M. Hadgis of Morgan, Lewis & Bockius LLP (“Defendants’ 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