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NOW THEREFORE, in consideration of the foregoing and the following statements,
<br />covenants, promises, obligations and undertakings, it is mutually agreed by and between the
<br />Parties, as follows:
<br />SETTLEMENT TERMS
<br />1. Procedural Matters:
<br />1.1 Within 30 calendar days of executing this Agreement, if not already done so,
<br />CORTEZ shall cause to be prepared, and filed, and serve all the necessary and appropriate forms
<br />with the applicable Court so that the Court may hear CORTEZ's Petition for the Court's
<br />Approval of a Minor's Compromise according to the settlement outlined herein.
<br />1.2 As soon as possible before, and no later than, the filing date of the Petition for the
<br />Court's Approval of the Minor's Compromise, CORTEZ shall provide, in writing, to all Parties'
<br />counsel:
<br />(1) the name, complete address, telephone number(s), and Federal TIN of each third
<br />party, if any, including, but not limited to, any healthcare professional(s) and/or healthcare
<br />facility or company, federal, state, local agency or entity that has, may have, or purports to have
<br />a statutory lien as to the outcome of this claim and/or the Settlement Amount;
<br />(2) the amount of all current liens, contracts, claims, obligations, debts, contracts,
<br />encumbrances, if any, by or with any third parties, including, but not limited to, any healthcare
<br />professional(s) and/or healthcare facility or company, federal, state, local agency or entity that
<br />has, may have, or purports to have a statutory lien as to the outcome of this claim and/or the
<br />Settlement Amount; and
<br />(3) the negotiated and discounted final amount, if different from those identified pursuant
<br />to Section 1.2(2), above, of each current lien, contract, claim, obligation, debt, encumbrance by
<br />or with any healthcare professional(s) and/or healthcare facility or company, federal, state, local
<br />agency or entity that has, may have, or purports to have a statutory lien as to the outcome of this
<br />claim and/or the Settlement Amount which said lien holder, or the like, has agreed to accept as
<br />full and final payment and satisfaction of any such liens, contracts, claims, obligations, debts,
<br />contracts, encumbrances.
<br />1.3 All checks consistent with the Settlement Amount and any payments to any lien-
<br />holder(s), if any, will be held in trust by each respective payor Party's counsel until such time as
<br />required by this Agreement and the Court's approval of the Minor's compromise, when said
<br />checks will be transmitted to CORTEZ's counsel for distribution.
<br />1.4 Within thirty (30) calendar days of the Court's approval of the Minor's
<br />compromise, the Settlement funds and any check(s) payable to any lien -holders, if any, will be
<br />contemporaneously exchanged for an executed Request for Dismissal, with prejudice, as to any
<br />and all cases, claims, causes of action and as to any and all parties. Within thirty (30) calendar
<br />days of the Court's approval of the Minor's compromise, all Parties agree to provide to counsel
<br />[2]
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