SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • January 17th, 2025 • Alabama
Contract Type FiledJanuary 17th, 2025 JurisdictionThis Settlement Agreement1 is entered into by and among Plaintiffs Jeremy Hufstetler, Adam Runk, Connie Hatfield, Yashvantsinh Jhala, Dale Stark, Lisa Kenny, A’Tavion Morrissette, Gene Sawyer, Robert Moffa, Leah Harner, and Judy Young (collectively, “Plaintiffs” or “Named Plaintiffs”), for themselves and on behalf of the Settlement Class, and Defendants Upstream Rehabilitation, Inc. and Upstream RollCo LLC d/b/a Upstream Rehabilitation (“Upstream” or “Defendants”), subject to preliminary and final Court approval. As provided herein, Defendants and the Named Plaintiffs hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against the Defendants in connection with the Data Security Incident as alleged in the action titled Jeremy Hufstetler et al. v. Upstream Rehabilitation Inc., et al., Case No. 01-CV-2024-902563.00, pending in the Circuit Co