Common Contracts

SECOND AMENDED SETTLEMENT AGREEMENT

December 15th, 2023

• Filed
  December 15th, 2023

This Second Amended Settlement Agreement, effective as of the last date of execution hereof (the “Effective Date”), is made and entered into by and among the following Settling Parties (as defined below): (i) Rudolph M. Franchi and Carlos Aragon (“Representative Plaintiffs”), individually and on behalf of the Settlement Class (as defined below), by and through their respective counsel at Clayeo C. Arnold, Professional Corp., Chestnut Cambronne PA, Markovits, Stock & DeMarco, LLC, Milberg Coleman Bryson Phillips Grossman, PLLC, and Morgan & Morgan Complex Litigation Group (collectively, “Proposed Class Counsel” or “Class Counsel”); and (ii) Barlow Respiratory Hospital (“Barlow” and, together with Representative Plaintiffs, the