CLASS ACTION SETTLEMENT AGREEMENTClass Action Settlement Agreement • April 15th, 2025
This Settlement Agreement,1 dated as of November 18, 2022 is made and entered into by and among the following Settling Parties: Ann St. James, Relina Alvarado, Timothy Kennedy, Thomas Shriver, James Lee, Brandyn Gomes, Neil Kenney, William Yost, Alesha Blake, Anthony Hingtgen, and Stacey Ohn Manybanseng in their individual capacities and on behalf of all others similarly situated (collectively, “Plaintiffs”), individually and on behalf of the Settlement Class, by and through their counsel of record, and Partnership HealthPlan of California (“PHC”or “Defendant” and, together with Plaintiffs, the “Settling Parties”), by and throughtheir counsel of record. 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 Released Claims, upon and subject to the terms and conditions hereof.