CLASS ACTION SETTLEMENT AGREEMENT AND RELEASEClass Action Settlement Agreement • March 8th, 2024
Contract Type FiledMarch 8th, 2024This Agreement (“Agreement,” “Settlement,” or “Settlement Agreement”) is entered into by and among (i) Plaintiff, Katherine Miller (“Plaintiff” or “Miller”); (ii) the Settlement Class (as defined herein); and (iii) Defendants, Jerry Erwin Associates LLC, Amber Glen LLC, Mill Creek, LLC, Sugar Creek, LLC, Peoria EE Group, LLC, and Senior Living EE Group (collectively, “Defendants”). Plaintiff and Defendants are collectively referred to herein as the “Parties.” This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined herein), upon and subject to the terms and conditions of this Agreement, and subject to the final approval of the Court.