SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • March 10th, 2025
This Settlement Agreement, dated as of the Effective Date, is made and entered into by and among the following Settling Parties (defined below): (i) Plaintiff Barbara Horvath (“Representative Plaintiff”), individually and on behalf of the Settlement Class (defined below), by and through Milberg Coleman Bryson Phillips Grossman, PLLC (“Class Counsel”), on the one hand; and (ii) Defendant Gramercy Surgery Center, Inc. (“GSC” 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.