AGREEMENT TO SETTLE CLAIMSSettlement Agreement • November 4th, 2019 • Washington
Contract Type FiledNovember 4th, 2019 JurisdictionThis Agreement to Settle Claims (“Agreement”) is between plaintiff J.R., by and through his parents Ju.R. and Ja.R. (“Named Plaintiffs”), the “Settlement Class” (as defined in Section 1.21), and defendants Catholic Health Initiatives Medical Plan, as it currently is named and may be renamed in the future (the “Plan”) and CommonSpirit Health (formerly known as Catholic Health Initiatives) (referred to herein as “Catholic Health Iniatives” or “CHI”) (collectively referred to herein as the “CHI Defendants”) and Blue Cross Blue Shield of Illinois, a division of Health Care Service Corporation (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.