SETTLEMENT AGREEMENTSettlement Agreement • March 25th, 2021 • California
Contract Type FiledMarch 25th, 2021 JurisdictionThis Settlement Agreement and Release dated October 20, 2020 (the “Agreement”), is made and entered into by and among Plaintiffs A.B., C.D., E.F. G.H., I.J., K.L., and M.N. in the above-captioned consolidated action (“Plaintiffs”), through their undersigned counsel, Defendant Regents of the University of the California (“Regents”), and Defendant James Heaps, M.D. (together, “Releasing Defendants,” and collectively with Plaintiffs, the “Parties”). The Agreement is intended to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined herein) as against the Released Parties (as defined herein), subject to the approval of the Court and the terms and conditions set forth in this Agreement.