Common use of Participating Class Members’ Release Clause in Contracts

Participating Class Members’ Release. After the Judgment is final and Defendant has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for claims based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release Released Parties from all claims that were alleged, or reasonably could have been alleged, through the Class Period, based on the facts stated in the Operative Complaint and ascertained in the course of the Action, including but not limited to claims for (1) failure to pay overtime; (2) failure to authorize and/or permit meal breaks or pay lawful premiums; (3) failure to authorize and/or permit rest breaks; (4) failure to reimburse for business-related expenditures; (5) failure to furnish accurate wage statements; (6) waiting time penalties; (7) unfair business practices; and (8) violation of Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., as well as any and all wage and hour claims asserted or which could have been asserted based on the factual allegations contained in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Class Period. Except as set forth in paragraph 5.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.

Participating Class Members’ Release. After the Judgment is final and Defendant has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for claims based on the facts alleged in the Action for the Class Period facts and or the PAGA penalties based on PAGA Period factsPeriod, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release and discharge the Released Parties from all claims, transactions, or occurrences that occurred during the Class Period and PAGA Period, including but not limited to: (i) all claims that were alleged, or reasonably could have been alleged, through the Class Period, based on the facts stated contained in the Operative Complaint and or ascertained in the course of the Action, including but not limited to claims for (1) failure to pay overtime; (2) failure to authorize and/or permit meal breaks or pay lawful premiums; (3) failure to authorize and/or permit rest breaks; (4) failure to reimburse for business-related expenditures; (5) failure to furnish accurate wage statements; (6) waiting time penalties; (7) unfair business practices; and (8) violation of Labor Code sections 200ii) all PAGA claims, 201whether representative or individual in nature, 202that were alleged, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., as well as any and all wage and hour claims asserted or which reasonably could have been asserted alleged, based on the factual allegations facts contained in the Operative Complaint, through PAGA notice(s), or ascertained in the Class Period, including, but not limited to, any course of the Action. Such class and all PAGA claims include claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under violation of Labor Code sections 200510 and 1198 (unpaid overtime), 201violation of Labor Code sections 226.7 and 512(a) (unpaid meal period premiums), 202violation of Labor Code section 226.7 (unpaid rest period premiums), 203violation of Labor Code sections 1194 and 1197 (unpaid minimum wages), 218.5violation of Labor Code sections 201 and 202 (final wages not timely paid), 226violation of Labor Code section 226(a) (non-compliant wage statements), 226.7violations of Labor Code sections 2800 and 2802 (unreimbursed business expenses), 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, violation of Business and & Professions Code section 17200 17200, et seq., and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Class Period. Except as set forth in paragraph Section 5.3 of this the Settlement Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.

Participating Class Members’ Release. After the Judgment is final and Defendant has Defendants have fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant Defendants or related entities for claims wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release Released Parties from all causes of action and claims that were alleged, alleged in the Action or reasonably could have been alleged, through the Class Period, alleged based on the facts stated and legal theories contained in the Operative Complaint and ascertained in the course operative complaint, including all of the Action, including but not limited to following claims for relief: (1) failure to pay overtime; minimum wage for all hours worked in violation of Labor Code sections 1194 and 1194.2, and the Applicable Wage Orders; (2) failure to authorize and/or permit meal breaks or pay lawful premiumsall split shift premiums in violation of Labor Code sections 1197 and 1198, and the Applicable Wage Orders; (3) failure to authorize and/or permit rest breakspay proper overtime wages in violation of Labor Code sections 510, 1197, and 1198, and the Applicable Wage Orders; (4) failure to reimburse for business-related expendituresprovide compliant rest periods and pay missed rest break premiums in violation of Labor Code section 226.7 and the Applicable Wage Orders; (5) failure to furnish accurate wage statements; (6) waiting time penalties; (7) unfair business practices; provide compliant meal periods and (8) pay missed meal period premiums in violation of Labor Code sections 200226.7 and 512, and the Applicable Wage Orders; (6) failure to maintain accurate employment records in violation of Labor Code section 1174; (7) failure to pay timely wages during employment in violation of Labor Code sections 204, 210; (8) failure to pay all wages due and owing at separation in violation of Labor Code sections 201, 202, and 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, ; (9) failure to provide complete and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., as well as any and all accurate wage and hour claims asserted or which could have been asserted based on the factual allegations contained statements in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under violation of Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, 226 and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Class Period. Except as set forth in paragraph 5.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.226.3; and

Participating Class Members’ Release. After the Judgment is final and Defendant Quail Lodge has fully funded the Gross Settlement and separately paid all Settlement, including any employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant Quail Lodge or related entities for claims wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release Released Parties from (i) all claims that were alleged, or reasonably could have been alleged, through the Class Period, based on the Class Period facts stated in the Operative Class Action Complaint and ascertained in the course of the Actionincluding, including but not limited to claims for e.g., (1) failure to pay overtimefor all hours worked, including overtime hours worked; (2) failure to authorize and/or permit meal breaks or pay lawful premiumsminimum wage for all hours worked; (3) failure to authorize and/or permit rest provide compliant meal breaks; (4) failure to reimburse for business-related expendituresprovide compliant breaks; (5) failure to furnish accurate wage statementsprovide place of employment that is safe and healthful; (6) waiting time penaltiesfailure to reimburse for required business expenses; (7) unfair business practicesfailure to pay accrued vacation upon separation; (8) failure to timely pay all wages owed, and (8) violation 9) failure to provide accurate itemized wage statements and violating record keeping requirements, based on the following sections of the California Labor Code sections Code: 200-204, 201218, 202, 203, 218.5222, 226, 226.7, 500227.3, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., as well as any and all wage and hour claims asserted or which could have been asserted based on the factual allegations contained in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 11941197, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq.6400-6404, and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Class Period6407. . Except as set forth in paragraph 5.3 Section 6.3 of this the Settlement Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.

Participating Class Members’ Release. After the Judgment is final and Defendant has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the fro▇ ▇he Class SettlementSettl▇▇▇nt, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant or related entities for claims wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action for the duration of the Class Period and PAGA Period, which are resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release the Released Parties from all claims that were alleged, or reasonably could have been alleged, through the Class Period, based on the facts stated in the Operative Complaint and ascertained in the course of the ActionComplaint, including but not limited to claims for (1) failure to pay overtime; (2) failure to authorize and/or permit minimum wages; meal breaks or pay lawful period premiums; (3) failure to authorize and/or permit rest breaksbreak premiums; (4) failure to reimburse for business-related expendituresvested vacation; (5) failure to furnish accurate wage statements; (6) waiting time penalties; (7) unfair business practicesexpense reimbursement; and (8) violation based on violations of Labor Code sections 200, 201201- 204, 202204.1, 203208, 218.5210, 218.6, 221, 222, 223, 226, 226.3, 226.7, 500227.3, 246, 256, 510, 512, 558, 1194, 1194.2, 1197, 1197.1, 1198, 1199, 2802, and all applicable IWC Wage OrdersOrder 9, including §§ 3(A), 4, 3(A), 11, 12, or Industrial Welfare Commission Order #4, or Business and Professions Code section 17200 17200, et seq., as well as any and all wage and hour claims asserted or which could have been asserted based are premised on the factual allegations contained in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damagessame allegations, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Cal. Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seqRegs., and any and all claims or potential claims tit. 8, section 11090 (the “Released Class Claims”). The operative release period for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Released Class Claims is the Class Period. Except as set forth in paragraph 5.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ workers’ compensation, or claims based on facts occurring outside the Class Period.

Participating Class Members’ Release. After the Judgment is final and Defendant KW International, Inc. has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant KW International, Inc. or related entities for claims wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release Released Parties from all claims that were alleged, or reasonably could have been alleged, through the Class Period, based on the Class Period facts stated in the Operative Complaint and ascertained in the course of the Action, including but not limited to any and all claims involving claims for (1) failure to pay overtime; (2) all minimum wages, failure to authorize and/or permit meal breaks or pay lawful premiums; (3) all overtime wages, failure to authorize and/or permit provide rest breaks; (4) periods and pay missed rest period premiums, failure to reimburse for business-related expenditures; (5) provide meal periods and pay missed meal period premiums, failure to pay all wages earned and unpaid at separation, failure to furnish accurate itemized wage statements; , and unfair competition (6) waiting time penalties; (7) unfair business practices; and (8) violation of Labor Code sections 200, 201, 202, 203, 218.5204, 210, 226, 226(a), 226(e), 226.3, 226.7, 500, 510, 512, 516, 558, 1182.12, 1194, 1194.2, 1197, 1197.1, 1198, 28021199; Code of Civil Procedure section 1021.5, Civil Code sections 3287(b) and 3289, and all applicable IWC Wage Orders, Business and Professions Code section sections 17200 et seq., as well as any and all wage and hour claims asserted or which could have been asserted based on the factual allegations contained in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Class Period). Except as set forth in paragraph Section 5.3 of this the Settlement Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.

Participating Class Members’ Release. After the Judgment is final and Defendant has Defendants have fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant Defendants or related entities for claims wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action for the duration of the Class Period and PAGA Period, which are resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release the Released Parties from all claims that were alleged, or reasonably could have been alleged, through the Class Period, based on the facts stated in the Operative Complaint and ascertained in the course of the ActionComplaint, including but not limited to claims for (1) failure to provide meal and rest breaks, failure to pay overtime; (2) failure for meal and rest break premiums pay in lieu thereof and at the correct rates paid for same, pay overtime wages and the correct rates paid for same, pay minimum or regular wages for all hours worked, pay timely wages during employment, pay all earned and accrued wages to authorize and/or permit meal breaks or pay lawful premiums; (3) failure to authorize and/or permit rest breaks; (4) failure to reimburse for business-related expenditures; (5) failure to discharged/separated employees, furnish accurate itemized wage statements; (6) waiting time penalties; (7) unfair , maintain required payroll records, and indemnify employees for business practices; expenses, and (8) violation based on violations of Labor Code sections 200-204, 201208, 202210, 203, 218.5218.6, 226, 226.2, 226.3, 226.7, 500, 510, 512, 558, 1174, 1174.5, 1194, 1194.2, 1197, 1197.1, 1198, 1198.5, 1199, 2802, and all applicable IWC Wage Ordersor Industrial Welfare Commission Order #4, or Business and Professions Code section 17200 17200, et seq., as well as any and all wage and hour claims asserted or which could have been asserted based are premised on the factual allegations contained in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damagessame allegations, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Cal. Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seqRegs., and any and all claims or potential claims tit. 8, section 11090 (the “Released Class Claims”). The operative release period for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Released Class Claims is the Class Period. Except as set forth in paragraph 5.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.

Participating Class Members’ Release. After the Judgment is final and Defendant has Defendants have fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant Defendants or related entities for claims wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release Released Parties from (i) all claims that were alleged, or reasonably could have been alleged, through the Class Period, based on the facts stated in the Operative Complaint and ascertained in the course of the Action, including but not limited to claims for (1) including: failure to pay overtimeall regular and minimum wages; (2) failure to authorize and/or permit meal breaks or pay lawful premiumsall overtime wages; (3) failure to authorize and/or permit rest breaksprovide meal periods; (4) failure to reimburse for business-related expendituresprovide rest periods; (5) untimely payment of wages; failure to furnish accurate pay wages due at termination; failure to provide itemized wage statements; (6) failure to pay employees twice a month; waiting time penalties; (7) unfair failure to reimburse business practicesexpenses; failure to provide records; violations of Business and (8) violation of Professions Code section 17200, et seq.; PAGA claims for civil penalties due to the alleged Labor Code violations and by Defendants during the Class Period including California Labor Code sections 200201-204, 201, 202, 203, 218.5210, 226, 226.3, 226.7, 500432, 510, 512, 516, 558, 1174, 1182.12, 1194, 1197, 1197.1, 1198, 28021198.5, 1199, 2802 and all applicable IWC Wage Orders, Business and Professions Code section 17200 2698 et seq., as well as any IWC Wage Order 4-2001; Cal. Code of Regulations sections 11040(11) and all wage and hour claims asserted or which (12); penalties that could have been asserted based on arisen out of the factual allegations contained facts alleged in the Operative Complaint or First Amended Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, including waiting time penalties, liquidated damageswage statement penalties, and all other associated damages and/or statutory breaks penalties, including but not limited to damages and/or penalties for claims under Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, ; interest; attorneys’ fees and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., costs; and any other claims arising out of or related to the Complaint and all claims or potential claims for lost wages and/or benefitsthe First Amended Complaint, consequential economic damagesfrom December 20, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, 2017 through the Class Perioddate of Preliminary Approval. Except as set forth in paragraph Section 5.3 of this the Settlement Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.

Participating Class Members’ Release. After the Judgment is final and Defendant MSMU has fully funded the Gross Settlement and separately paid all employer payroll taxesSettlement, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant MSMU or related entities the Released Parties, for claims based on the Class Period facts and PAGA penalties based on PAGA Period the facts, as alleged in the Action and resolved by this Settlement. Released Parties means MSMU and all of its affiliated entities including its founders and members (the Sisters of St. ▇▇▇▇▇▇ ▇▇ ▇▇▇▇▇▇▇▇▇▇), as well as any of its past, present and future officers, agents, directors, shareholders, principals, partners, owners, trustees, supervisors, administrators, staff members, non-Class Member employees, representatives, parents, subsidiaries, attorneys, sureties, bonding companies, insurers, risk pooling trusts, and legal predecessors, successors, heirs, executors, administrators, assigns, and all persons acting by, through, under, or in concert with any of them. The Participating Class Members will be bound by the following release: All : 1.1 Each and all Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, shall be deemed to release MSMU and the Released Parties from all claims that were alleged, or reasonably could have been alleged, through based on the Class Period facts alleged on their behalves in the operative First Amended Complaint, and arising during the Class Period, based on the facts stated in the Operative Complaint and ascertained in the course of the Action, including but not limited to claims for (1) failure to pay overtime; (2) failure to authorize and/or permit meal breaks or pay lawful premiums; (3) failure to authorize and/or permit rest breaks; (4) failure to reimburse for business-related expenditures; (5) failure to furnish accurate wage statements; (6) waiting time penalties; (7) unfair business practices; and (8) violation of under Labor Code sections 200§§ 226.2, 2011194, 202, 203, 218.5, 2261194.2, 226.7, 500226(a) & (e), 510, 512, 558, 1194, 1198, 2802201-203, and all applicable IWC Wage Orders, 2802; and Business and Professions Code section §§ 17200 et seq., as well as any and all wage and hour claims asserted or which could have been asserted based on the factual allegations contained in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Class Period. Except as set forth in paragraph 5.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.

Participating Class Members’ Release. After the Final Order and Judgment is final entered and Defendant has fully funded the Gross Settlement Amount (and separately paid all employer payroll taxes), Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant concerning the legal claims being resolved in this Settlement or related entities for claims that could have been brought in the Action based on the Class Period same facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this SettlementAction. Specifically, you will be giving up or “releasing” the claims described below: The Participating Class Members will be bound by the following release: All Participating Class MembersMembers are fully and irrevocably releasing the Released Parties [San Antonio Regional Hospital, on behalf of themselves and its affiliates, divisions, subsidiaries, parents, predecessors, any merged entity or merged entities and/or its or their respective present and former and present representativesofficers, partners, directors, managers, supervisors, employees, attorneys, agents, attorneysshareholders and/or successors, spousesassigns, trustees, heirs, administrators, successorsexecutors, representatives and/or principals thereof] from in exchange for the consideration provided by this Settlement Agreement, including any and all claims, demands, rights, liabilities, and assignscauses of action under any federal, release Released Parties from all claims that were allegedstate or local law, or reasonably statute that have been or could have been alleged, through asserted in the instant Class Action based on the allegations in the operative Class Complaints in the Class Action for the duration of the Class Period, based on the facts stated in the Operative Complaint and ascertained in the course of the Action, including but not limited to to, claims for for: (1) failure to pay overtime; (2) failure to authorize and/or permit meal breaks or pay lawful premiums; (3) failure to authorize and/or permit rest breaks; (4) failure to reimburse for business-related expenditures; (5) failure to furnish accurate wage statements; (6) waiting time penalties; (7) unfair business practices; and (8) violation of Labor Code sections §§ 200, 201, 202, 203, 218.5204, 226210, 226.7, 500246, 510, 512, 558, 1194, 11981194.2, 1197, 1198 and IWC Wage Orders (failure to pay wages / failure to pay minimum wages); (2) violation of Labor Code §§ 510 and 1194 and IWC Wage Orders (failure to pay overtime wages); (3) violation of Labor Code §§ 226.7, 512 and IWC Wage Orders (failure to provide required meal periods); (4) violation of Labor Code §§ 226.7 and IWC Wage Orders (failure to permit rest breaks); (5) violation of Labor Code § 246 (failure to provide sick pay); (6) violation of Labor Code §§ 201, 202 and 203 (failure to pay all wages due upon separation of employment / failure to pay timely wages; (6) violation of Labor Code §§ 204 and 226 (failure to furnish accurate wage statements); (7) violation of Labor Code §§ 2800 and 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., as well as any and all wage and hour claims asserted or which could have been asserted based on other sections of the factual allegations contained in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under California Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and California Wage Orders that pertain to unreimbursed business expenses (failure to reimburse all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Class Period. Except as set forth in paragraph 5.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.business expenses); and

Participating Class Members’ Release. After the Judgment is final and Defendant EDNET has fully funded the Gross Settlement Amount and separately paid funds all employer payroll taxestaxes owed on the Wage Portion of the Individual Class Payments, Plaintiff, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant EDNET or related entities for claims wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action Action, and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Upon entry of the final judgment and funding of the Gross Settlement Amount, all Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release Released Parties from all wage and hour claims that were alleged, alleged or reasonably could have been alleged, through the Class Period, based on the facts stated alleged in the Operative Complaint relating to wage and ascertained in the course of the Action, hour claims including but not limited to any and all claims for (1) involving any alleged unpaid overtime and/or minimum wage under Labor Code sections 510, 1194, 1197, 1197.1 and 1198, failure to provide meal and rest periods pursuant to Labor Code sections 204, 226.7, 510,512, and 1198, alleged unreimbursed business expenses under Labor code section 2802, alleged failure to provide and maintain accurate records violations under Labor Code sections 226(a)/(f)/(h),, alleged failure to pay overtime; (2) failure to authorize and/or permit meal breaks or pay lawful premiums; (3) failure to authorize and/or permit rest breaks; (4) failure to reimburse for business-related expenditures; (5) failure to furnish accurate wage statements; (6) waiting time penalties; (7) unfair business practices; and (8) violation of wages during employment under Labor Code sections 200204, 210, alleged failure to pay wages after under employment Labor Code sections 201, 202, -203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, alleged violation of California Business and & Professions Code section 17200 et seq.. (Unfair Competition Law) arising from the labor code violations listed hereinabove from August 6, 2016 to September 23, 2022 (“Class Period”). This release will be as well as any to the Released Parties, which shall include EdNet Career Institute (dba ▇▇▇▇▇▇▇▇ Private Security), and all wage each of its former and hour claims asserted or which could have been asserted based on present directors, officers, shareholders, owners, members, attorneys, insurers, predecessors, successors, assigns, subsidiaries and/or affiliates. The release shall be effective with respect to the factual allegations contained in Settlement Class Members who do not validly opt-out of the Operative ComplaintClass Settlement, through who worked for Defendant during the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., and any and all claims or potential claims for lost wages and/or benefits, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through . The release shall be effective upon final approval of the Class PeriodSettlement and funding in full of the Fund by Defendant. Except as set forth in paragraph 5.3 Section 6.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period. This release expressly excludes PAGA penalties, which are separately released hereinbelow.

Participating Class Members’ Release. After the Judgment is final and Defendant has Defendants have fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendant Defendants or related entities for claims wages based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement. The Participating Class Members will be bound by the following release: All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, spouses, heirs, administrators, successors, and assigns, release Released Parties from (i) all claims that were alleged, or reasonably could have been alleged, through the Class Period, based on the Class Period facts stated in the Operative Complaint Complaints and ascertained in the course of the ActionAction , including but not limited to claims for (1) failure to pay overtime; all earned wages, (2) failure to authorize and/or permit meal breaks or pay lawful premiums; unpaid minimum wages, (3) failure to authorize and/or permit rest breaks; unpaid overtime wages, (4) failure to reimburse for business-related expenditures; provide meal periods, (5) failure to furnish provide rest periods, (6) failure to provide accurate wage statements; , (67) waiting time penalties; , (78) failure to maintain accurate payroll, (9) failure to pay all wages earned for labor performed each pay period, (10) failure to indemnify for all necessary business expenditures, (11) unfair business practices; and (8) violation of Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, competition pursuant to California Business and Professions Code section 17200 et seq.17200, as well as any and all wage and hour claims asserted or which could have been asserted based on the factual allegations contained in the Operative Complaint, through the Class Period, including, but not limited to, any and all claims for unpaid wages, economic damages, non- economic damages, any other damages, statutory penalties, waiting time penalties, liquidated damages, and all other associated damages and/or statutory penalties, including but not limited to damages and/or penalties for claims under Labor Code sections 200, 201, 202, 203, 218.5, 226, 226.7, 500, 510, 512, 558, 1194, 1198, 2802, and all applicable IWC Wage Orders, Business and Professions Code section 17200 et seq., and any and all claims or potential claims for lost wages and/or benefits(12) violation of California Labor Code section 2698, consequential economic damages, other economic damages, punitive damages, any other damages, attorneys' fees and costs and interest, through the Class Periodet seq. Except as set forth in paragraph 5.3 Section 6.3 of this Agreement, Participating Class Members do not release any other claims, including claims for vested benefits, wrongful termination, violation of the Fair Employment and Housing Act, unemployment insurance, disability, social security, workers’ compensation, or claims based on facts occurring outside the Class Period.