SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • November 25th, 2024
This Settlement Agreement, dated as of the Effective Date, is made and entered into by and among the following Settling Parties (defined below): (i) Plaintiffs Donna Brim, Kimberly Perry, and Janet Turner Lamonica (“Representative Plaintiffs”), individually and on behalf of the Settlement Class (defined below), by and through Tousley Brain Stephens PLLC, Milberg Coleman Bryson Phillips Grossman, PLLC, Chestnut Cambronne PA, Mason LLP, and Frank Freed Subit & Thomas LLP (“Class Counsel”), on the one hand; and (ii) Defendant Prestige Care, Inc. (“Prestige Care” or “Defendant”), by and through its counsel of record, Mullen Coughlin LLC (“Defendant’s Counsel”) on the other hand. The Settlement Agreement is subject to Court approval and is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Litigation (defined below) and the Released Claims (defined below), upon and subject to the terms and conditions below.