AMENDED CLASS ACTION AND PAGA SETTLEMENT AGREEMENT Class Action and Paga Settlement Agreement • June 8th, 2023 • California
This Amended Class Action and PAGA Settlement Agreement (“Agreement” or “Settlement”) is made by and between Plaintiffs Wilbert Wells, Paul Vu, Daniel Navarro, Andrew Ortega, Davitshea Singletary, Kareem Terry, John Nelson, Richard Vasquez, Joseph Charogoff, Martin Felix, Sam Blagovich, Pedro Vargas, Jr., Luis Lomeli, Mariah Bravo, Slyvira Brewer, and Sherry Morrow (collectively “Plaintiffs”) and Defendant San Gorgonio Medical Hospital (“Defendant”). The Agreement refers to Plaintiffs and Defendant collectively as “Parties,” or individually as a “Party.”