SETTLEMENT AGREEMENTSettlement Agreement • May 27th, 2021 • California
Contract Type FiledMay 27th, 2021 JurisdictionThis Settlement Agreement and Release of All Claims (“Agreement”) is made and entered into by and between Carla Gatlin in her individual capacity, and as successor in interest of decedent Baylee Ybarra Gatlin and Susan Ybarra Telias in her individual capacity and as successor in interest of decedent (hereinafter “Plaintiffs”) on the one hand, and Defendants Do Lab Inc., and Richard Gottlieb, individually and d.b.a RGX Medical, (hereinafter Defendants) on the other hand, (collectively, “the Parties”) based upon the following recital of facts: