Scope of this Settlement Agreement. The Parties agree that this Settlement Agreement is meant to fully address, resolve, and settle all class-wide claims contained in counts 1 through 6 of Plaintiffs’ Complaint and the relief requested in connection with those claims. The Parties agree that the class-wide claims contained in counts 1 through 6 do not cover acts or omissions under the final plans or new resource allocation model that the Department must develop under this Settlement Agreement. The individual claims, contained in counts 7 through 10 in Plaintiffs’ Complaint, remain unresolved and are set to proceed to trial in this matter.
Scope of this Settlement Agreement. (a) This Settlement Agreement settles all aspects of and relief requested in the Application, except for the Excluded Items identified in section 2 below.