SETTLEMENT AGREEMENT AND RELEASE OF LIABILITYJuly 24th, 2024
FiledJuly 24th, 2024It is the intent of the parties to this Settlement Agreement and Release of Liability (the “AGREEMENT”) to fully settle all claims and potential claims against the State of Tennessee, including its employees, agents, agencies, and instrumentalities (collectively, the “STATE”), that relate to or arise out of Counts IV, V, VI, VII, VIII, and X of the complaint filed by Michelle Anderson, Jane Doe 2, Jane Doe 3, Jane Doe 4 (collectively, “INDIVIDUAL PLAINTIFFS”) and OUTMemphis (collectively with the INDIVIDUAL PLAINTIFFS, “PLAINTIFFS”) against Governor Bill Lee, Attorney General Jonathan Skrmetti, TBI Director David Rausch (“TBI”), and TDOC Commissioner Frank Strada (collectively, “DEFENDANTS”), captioned OUTMemphis v. Lee, No. 2:23-cv-2670 (W.D. Tenn.). This release does not prejudice INDIVIDUAL PLAINTIFFS’ ability to obtain compensation recovered by the United States in United States v. Tennessee, No. 2:24-CV-2101 (W.D. Tenn.) to the extent available.