EFTA00726467.pdf

Section 3(a) The Parties agree that the amount of this settlement shall be kept strictly confidential and shall not be disclosed at any time to any third party, except: (a) immediate family members of the Parties (whose identities must be provided as "Eyes Only" to Sidney Stubbs, Esq., Special Master, in a sealed envelope to be opened only if a third party is alleged to have breached this provision) . . . Section 7 This settlement does not include any amounts for attorneys' fees or costs. The Parties and their attorneys have agreed to resolve the amount of attorneys' fees and costs throw Special Master whom they have mutually selected, Sidney Stubbs, Esq. agrees that any claims by her for attorneys' fees or costs is to be made solely through her attorneys and the Special Master proceeding. Section 8b agrees that it is her obligation to pay any outstanding bills relating to this matter from all healthcare providers, satisfy any healthcare provider obligations arising out of the injuries underlying her claim, and hold Second Parties harmless from same. This provision does not include health care evaluations, if any, which are costs that have been paid for by her attorneys. These costs will be subject to reimbursement by Second Parties, to the extent that they are for evaluation and not treatment. if the Parties do not agree as to whether these costs are for evaluation and not treatment, and/or do not agree as to the reasonableness of the amount claimed, then the Special Master will make those determinations. EFTA00726467