SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • March 11th, 2020 • Tennessee
Contract Type FiledMarch 11th, 2020 JurisdictionThis Settlement Agreement and Release (“Agreement”) is made and entered into on March 11, 2020, by and among (1) Plaintiffs, K.B., by and through her natural parent, Jennifer Qassis, and Lillian Knox-Bender (“Plaintiffs”), individually and on behalf of the Settlement Class, and (2) Methodist Healthcare – Memphis Hospitals (“Methodist”) (together, with Plaintiffs, the “Parties”), subject to preliminary and final approval as required by Tennessee Rule of Civil Procedure 23.05. As provided herein, Plaintiffs, Class Counsel, and Methodist hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and effective upon entry by the Court of a Final Order and Judgment, all claims of the Settlement Class against Methodist in the action titled K.B., by and through her natural parent, Jennifer Qassis, and Lillian Knox-Bender v. Methodist Healthcare – Memphis Hospitals, Chancery Court of Shelby County, 30th Judicial Circuit Memphis, No. CH-13-0487-1