STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • December 29th, 2021 • Wisconsin
Contract Type FiledDecember 29th, 2021 JurisdictionThis Stipulation and Agreement of Settlement, as of the date of execution below (the “Settlement Agreement,” “Settlement,” “Agreement,” or “Stipulation”), is made and entered into by and among the following settling parties (“Parties”): (i) Terri A. Goetz (“Plaintiff” or “Settlement Class Representative”), individually and on behalf of the Settlement Class (defined below); and (ii) Benefit Recovery Specialists, Inc. (“BRSI” or “Defendant”), and subject to preliminary and final Court approval as required by Wis. Stat. § 803.08(9). In consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final approval order and judgment, all claims of the Settlement Class against BRSI in the Action shall be settled and compromised upon the terms and conditions contained herein. This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle all of Plaintiff’s Released Claims (defined below), upon and subject to th