SETTLEMENT AGREEMENTSettlement Agreement • September 9th, 2015 • California
Contract Type FiledSeptember 9th, 2015 JurisdictionThis Settlement Agreement, dated September 10, 2015 (the “Settlement Agreement” or “Settlement”), is made and entered into by and among the following settling parties (“Settling Parties”): (i) Deanna DeBaeke, Danna Graewingholt, Jeannie Hambric, Linda Kerkow, and Desiree Ortiz (“Class Representatives”), individually and on behalf of the Settlement Class Members (as defined in ¶ 1.6 below); and (ii) St. Joseph Health System, Mission Hospital Regional Medical Center, St. Jude Hospital, Queen of the Valley Medical Center, Santa Rosa Memorial Hospital, Petaluma Valley Hospital Auxiliary, The Auxiliary of Mission Hospital Laguna Beach, The Auxiliary of Mission Hospital Mission Viejo, Saint Joseph Hospital of Orange, Saint Joseph Hospital of Eureka and Redwood Memorial Hospital of Fortuna (collectively, “Defendants”). The Settlement Agreement is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle all of Plaintiffs’ Released Claims (as defined in ¶ 1