youn to zane” s:0srH pragrionwirier a ley vs_ Univer (Case No.: 98-06438 CA CONFIDENTIAL SETTLEMENT MEMORANDUM The parties in the above-referenced case have entered into the following settlement agreement: 1. University Medical Center will pay to Shanara Mobley, subject to approval of the Court, the sum of $1,980,000.00 in full and final settlement of all claims that she has against University Medical Center, individually, and as the mother and natural guardian of Kamiyah Terestah Tasha Mobley, a miner. 2. After this settlement has been approved by the Court, Shanara Mobley will execute a Complete Release in favor of University Medical Center for all claims that she has individually against University Medical Center, of any kind and nature whatsoever, and of ali claims that she has against University Medical Center, of any kind and nature whatsoever, as the mother and natural guardian of Kamiyah Teresiah Tasha Mobley, a minor. 3. Shella Mobley, a nominal plaintiff in this action, shall execute a voluntary Notice of Dismissal With Prejudice of any claims that she might have either Individually or in a representative capacity. 4. Shanara Mobley, joined by her attorneys of record, shall execute a Confidentiality Agreement keeping confidential all terms and conditions of this settlement. 5, The total settlement emount of $1,990,000.00 shatl be paid as follows: (a) _ The amount of $1,265,000.00 shall be patd by check or draft to Shanara L. Mobley, individually, and as guardian and next friend of Kamiyah Teresiah Tasha Mobley and to Alford & Kalll, P.A., her attorneys. This amount shail be utilized to pay attorneys’ fees, costs and the cash portion of the settlement to be distributed to Shanara L. Mobley, individually, (b) The amount of $725,000.00 shall be paid directly by the Defendant to New York Life Insurance and Annuity Corporation for the purchase of an annuity on behalf of Shanara L. Mobley for future periodic payments as follows:2002 9:05°H ler ersbradvish ai) er v No-5498 P. 14/22 (1) To Shanara L. Mobley, individually, the amount of $3,644.00 per month for life, guaranteed for 20 years, commencing August 1, 2000. (2) Aportion of the settlement proceeds shall be used to purchase an-edusatienal fund on behalf of Kamiyah Teresiah Tasha Mobley (‘Kamiyah”). On July 10, 2076 this fund, in the amount of $307,644.00, shall be paid to Kamiyah if she Is located alive and is properly identified through DNA as being the natural child of Shanara L. Mobley. However, if Kamiyah is not located by July 10, 2016, or is iocated but dies prior to July 10, 2016, these funds shall be pald to Shanara L. Mobley on July 10, 2016. The insurance company shall be under no duty to ascertain whether or not Kamiyah has been found unless they are advised credible proof that Kamiyah is alive and requests payment of these funds, the insurance company is fully authorized to pay this amount of Kamiyah's mother, Shanara L. Mobley. The insurance company shall be held harmless for paying these funds to Shanara L. Mobley if Kamiyah {s not located by, or Is not alive on July 10, 2016 ‘The expected total benefits to be pald pursuant to the aforeszid annulty Is $3,062,08,00. 6. __ When this settlement and the terms hereof have been approved by the Court, Shanara L. Mobley, in both her individual and representative capacity, by and through her attomeys, will execute @ Stipulation of Dismissal With Prejudice which will be filed with the Court and upon which @ Final Order of Dismissal With Prejudice will be obtained from the Court. Dated this FA day of June, 2000. kant Ge Charles T. Shad, Esquire Attorney for University Medical Center, Inc. © Wayne Alford, Esquire Russell Healey, Esquire 5 Attornays for Plaintiff