STIPULATION AND AGREEMENT OF SETTLEMENTStipulation and Agreement • September 23rd, 2021 • Massachusetts
Contract Type FiledSeptember 23rd, 2021 JurisdictionThis Stipulation and Agreement of Settlement, as of the date of execution below (the “Settlement Agreement,” “Settlement,” “Agreement,” or “Stipulation”), is made and entered into by and among the following settling parties (“Parties”): (i) Bonita Joyner (“Plaintiff” or “Settlement Class Representative”), individually and on behalf of the Settlement Class (defined below); and (ii) Behavioral Health Network, Inc. (“BHN” or “Defendant”), and subject to preliminary and final Court approval as required by Rule 23 of the Massachusetts Rules of Civil Procedure. In consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final approval order and judgment, all claims of the Settlement Class against BHN in the Action shall be settled and compromised upon the terms and conditions contained herein. This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle all of Plaintiff’s and the Settlement Class Membe