Russo Settlement Agreement Sample Contracts

IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO
Russo Settlement Agreement • March 1st, 2022 • Ohio

This Settlement Agreement, dated as of March 1, 2022, is made and entered into by and among the following Settling Parties (as defined below): Kathleen Devine, Richard Rydzinski, and Deshawn Beckham (“Plaintiffs”), individually and on behalf of the Settlement Class (as defined below), by and through their counsel at MARKOVITS, STOCK & DEMARCO, LLC, MASON, LIETZ & KLINGER, LLP, THE LYON FIRM, LLC (“Proposed Settlement Class Counsel” or “Class Counsel” or “Plaintiffs’ Counsel”) and Health Aid of Ohio, Inc. (“Defendant” and, together with Plaintiffs, the “Parties”) by and through their counsel of record, Walter A. (Scott) Lucas at Weston Hurd, LLP and Claudia McCarron at Mullen Coughlin LLC. 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.

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