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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 />[21 <br />