AGREEMENT TO SETTLE CLAIMSSettlement Agreement • December 1st, 2015 • Oregon
Contract Type FiledDecember 1st, 2015 JurisdictionThis Agreement to Settle Claims (“Agreement”) is between P.S., a minor, by and through her parents, Kelly Alford-Smith and Duane Smith, Kelly Alford-Smith, the “Settlement Class” (as defined in ¶1.17) and N.B., a minor by and through his parents, L.B. and B.B. (collectively, “Claimants”) and Defendants State of Oregon and the Oregon Public Employees’ Benefit Board (collectively “Defendants,” defined in ¶1.10). Claimants and Defendants are referred to collectively as the “Parties.” This Agreement is a full expression of the agreements between the Parties.