Common Contracts

AGREEMENT TO SETTLE CLAIMS‌

Settlement Agreement • November 30th, 2020 • Washington

• Contract Type
  Settlement Agreement
• Filed
  November 30th, 2020
• Jurisdiction
  Washington

This Agreement to Settle Claims (“Agreement”) is between plaintiff D.T., by and through his parents K.T. and W.T. (“Named Plaintiffs”), the “Settlement Class” (as defined in Section 1.9), and defendants NECA-IBEW Family Medical Care Plan (the “Plan”) and the Board of Trustees of the NECA/IBEW Family Medical Care Plan, Salvatore J. Chilia, Robert P. Klein, Darrell L. McCubbins, Geary Higgins, Lawrence J. Moter, Jr., Kevin Tighe, Jerry Sims, and any other individual member of the Board of Trustees of NECA/IBEW Family Medical Care Plan (“Trustees”) (collectively, “Defendants”). Named Plaintiffs and Defendants are referred to collectively as the “Parties.” This Agreement is a full expression of the agreements between the Parties.