SETTLEMENT AGREEMENTSettlement Agreement • November 11th, 2020
Contract Type FiledNovember 11th, 2020This Settlement Agreement is entered into by and between Plaintiff Thomas Harold MacRae, by and through his Successor in Interest, Heather Watters; Plaintiff Francisca Denning, by and through her Successor in Interest Claudette Denning; Plaintiff Tomasita Hoffmann, by and through her Successor in Interest Gilda Molinar; and Plaintiff Lula Spear, on their own behalves and on behalf of others similarly situated (“Plaintiffs”), and Defendants Manor Care of Citrus Heights CA, LLC; Manor Care of Fountain Valley CA, LLC; Manor Care of Hemet CA, LLC; Manor Care of Palm Desert CA, LLC; Manor Care of Sunnyvale CA, LLC; Manor Care – Tice Valley CA, LLC; Manor Care of Walnut Creek CA, LLC (the “Facility Defendants”); and HCR Manor Care Services, LLC (“Services”) (Services together with the Facility Defendants are the “Settling Defendants”); Plaintiffs and Settling Defendants shall be collectively referred to herein as “Parties,” or singularly, a “Party.”