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SETTLEMENT AGREEMENT This Setlement Agreement (Agreement) is entered into among the United States of, ‘America, ating through the United States Department of Justice and on behalf ofthe Office of laspector General (O10-HHS) ofthe Department of Health and Human Services (HHS), the Defense Health Agency (DHA), acting on behalf ofthe TRICARE Program (collectively, the “United States"), Health Management Associates, Ine, now known as Health Management Associates, LLC, its subsidiaries and affiliates, and its parent (“HMA Parent” (collectively, “HMA"), and Relators Craig Brummer, M.D., Ralph Williams, Scot Plantz, M.D., Thomas L. Mason, M.D, Steven G. Folstad, M.D, Mid-Atlantic Emergency Medical Associates, “Incqucne Meyer, J Michael Cowling, and Paul Meyer calletvely, the “Relators”, through tei authorized representatives. Relators Mason, Folsta, and Mid-Atlantic Emergency Medical Associates are coletively refered to herein asthe “MEMA Relators." Collectively al ofthe above wil be refered to as the Fates.” RECITALS |A. Health Managemen Associates, in. i for-profit helth cae system that, during the relevant period, through its subsidiaries, indirectly owned and/or operated hospitals, throughout the United States. HMA Parent, « Delaware corporation with ts principal place of business in Franklin, Tennessee, cquied Health Management Associates, Inc, now known as Health Management Associates, LLC in January 2014 B. On November 24,2009, Relator Craig Brummer, M.D. led a aul tam action in the United States Dist Court fr the Norhem District of Georgia, captioned United States ex tel. Brummer». Health Management Associates, Inc, etal, No. 1:09-CV-3287 (N.D. Ga. pursuant tothe gu cam provisions of the False Claims Act, 31 U.S.C. § 3730(b), On December 14,2008, Reltor's motion to transfer venue tothe Middle Distt of Georgie was granted. The case was assigned case number Civil Action No, :09-CV-138 (CDL) following its wansfero the Middle District of Georgia (the “Brummer Civil Action”). On December 16,2013, the United States intervened inthe Brummer Civil Action, ©. OnDecember 12009, Relator Ralph D. Williams fled a gu am action inthe United States Distt Court forthe Middle District of Georgia, captioned United States exe. Wiliams y. Heath Mgmt. Assoes, eal, No. 3:08-CV-130 (CDL), pursuant othe qu tam provisions ofthe False Claims Act, 31 USC. §3730(6), On November 30, 2012, Relator Wiliams severed certain claims, and filed separate complaint with respetto the severed aims, captioned United Stats ex rel. Willams»: Health Mgmt Asoes, etal, No. 3:12-CV- 151 (CDL) (the “Wiliams Civil Action”). On December 16,2013, the United Stats intervened inthe Williams Civil Acton. D. On February 11,2010, Relator Ssot H. Plant, M.D. filed a gu tam ation in the United States District Cour forthe Norher Distt of lini, captioned United Stars ex rel Plants. Heath Management Associates et a, Case No. 10€ 0950, pursuant tothe gui tam provisions of the Fale Claims Act, 31 US.C. §3730(0). On February 14,2013, Relator Plantz filed his severed complaint against the HMA defendant ProMed, which was assigned Case No, 13 € 1212 (he “Plant Civil Action”), On December 16,2013, the United States intervened {in the Plant Civil Aeson with regard to certain claims against the HMA defendants, E.On September 23,2010, Relators Thomas Mason, M.D, Stephen Fostad, M.D. and ther medial practice Mid-Atlantic Emergency Medial Associates ("MEMA") filed «gui {am ation in the United States Diseict Court forthe Western District of North Carolina, captioned United Stars ex rel. Mason, Folstad & MEMA v. Heath Mgmt, Assoes, et al, No. 3:10-cv-472, pursuant to the qui tam provisions of the False Claims Act, 31 U.S.C. §3730(b) (the *MEMA Civil Action”). On April 18, 2011, the MEMA Relators filed theirsealed First ‘Amended Complaint. On April 12,2012, the MEMA Relators file their sealed Second ‘Amended Comple [Atthe United States request, the MEMA Relators severe certain claims and fled ther Severed Second Amended Complaint on January 9, 2013. On December 16, 2013, the United States intervened inthe MEMA Civil Action with egad to eerain claims sgainst the HMA defendants F OnJuly 15,2011, Relators Jacqueline Meyer and J. Michael Cowing fled a qu tam ation in the United States District Court foe the Distt of South Crotna, captioned Unied States ex ret. Meyer and Cowling v Health Mat. Assocs, ea, No, +1 -ev-O1713-IA, pursuant tothe gui tam provisions ofthe False Claims Act, 31 U.S.C. §3730(6) the “Meyer and Cowling Civil Action”). On December 16,2013, the United States intervened inthe Meyer and CCovling Civil Action with regard to certain claims against the HMA defendants G, On November 15,2011, Relator Paul Meyer filed a qui tam actior inthe United ‘States Distict Court forthe Souther District of Florida, captioned United States ex re. Paul Meyer v, Health Management Associates, Inc, etal, Civil Action No. 11-62445, pursuant tothe 4 1am provisions ofthe False Claims Act, 31 U.S.C. §3730(6) (the “Paul Meyer Civil ‘Action”), On December 16,2013, the United States intervened in the Paul Meyer Civil Action, H. The Brummer, Wi sms, Platz, MEMA, Meyer and Cowling, and Paul Meyer Actions ae hereater collectively refeted to as “the Civil Actions.” 1. OnJanuary 14,2014 he United States filed a motion wit the JuicialPanel on MultisrcLiigtion to consolidate the Civil Actions with thre oer False Claims Act gu! {am ations. On April 2, 2014, the Judicial Panel on Multis Litigation gerted the United States’ motion and assigned the cases othe Honorable Regaie Walton, United Sates District, Judge forthe District ofthe District of Columbia, for pre-trial proceedings. The HMA MDL is