SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • December 24th, 2016
Contract Type FiledDecember 24th, 2016This Settlement Agreement and Release (“Agreement”) is made and entered into, as of the date of the last signature required on this Agreement, by and among Plaintiffs Theresa Bartlow (“Bartlow”) and Robert A. McBride (“McBride” and collectively, “Plaintiffs”), individually and as representatives of the Settlement Class Members (as defined below) and Defendant Medical Facilities of America, Inc. (“MFA”), along with Medical Facilities of North Carolina, Inc (“MFNC”) and all related and affiliated skilled nursing facilities of either MFA or MFNC as identified on the attached Facilities Schedule (attached as Exhibit A) (collectively, “MFA et al.”). Plaintiffs and MFA et al. may be referred to collectively as the “Parties” throughout the remainder of this Agreement. This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined below), upon and subject to the terms and conditions herein.