SETTLEMENT AGREEMENT AND RELEASE OF CLAIMSSettlement Agreement • November 15th, 2023
Contract Type FiledNovember 15th, 2023This Settlement Agreement, is made and entered into by and among the following Settling Parties (defined below): (i) Natisha Palmer, David Jay Cain, Sharon Henderson, Vickie Wilhite, Steven Lightfoot, Billie Culp, Goldie Hicks, Gary Pugh and Daniel Arnold (“Plaintiffs”), individually and on behalf of the Settlement Class (defined below), by and through their counsel of record Mason LLP and Shub & Johns LLC (“Proposed Co-lead Class Counsel”), on the one hand; and (ii) Fitzgibbon Memorial Hospital, Inc. d/b/a Fitzgibbon Hospital (“Fitzgibbon”), by and through its counsel of record, McDonald Hopkins (“Fitzgibbon’s Counsel”) on the other hand. 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 Litigation (defined below) and the Released Claims (defined below), upon and subject to the terms and conditions below.