SETTLEMENT AGREEMENTSettlement Agreement • September 8th, 2023
Contract Type FiledSeptember 8th, 2023This Settlement Agreement, dated September 7, 2023, is made and entered into by and among the following Settling Parties (as defined below): (i) Joe Lara (“Plaintiff”), individually and on behalf of the Settlement Class (as defined below), by and through his counsel of record TURKE & STRAUSS LLP (“Plaintiff’s Counsel”); and (ii) Lubbock Heart Hospital, LLC, d/b/a Lubbock Heart & Surgical Hospital (“Defendant” or “Lubbock”), by and through its counsel of record, BAKER HOSTETLER LLP. The Settlement Agreement is subject to Court approval and is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined below), upon and subject to the terms and conditions hereof.