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6.1.H. - Page 3 <br /> SETTLEMENT AGREEMENT <br /> This Agreement of Settlement ("Agreement") is entered into by and between Plaintiff- <br /> Relator Jennifer Perez("Relator"), and defendant Stericycle, Inc. ("Stericycle"), through their <br /> authorized representatives. Relator and Stericycle are collectively the "Parties." <br /> RECITALS <br /> WHEREAS: <br /> A. Stericycle, based in Lake Forest, Illinois, is a provider of regulated medical waste <br /> management services and pharmaceutical returns services to medical offices, hospitals, other <br /> health care providers, and other entities. Stericycle does or has done business with government <br /> customers at the federal, state, and local government level ("Government Customers"). <br /> S. Relator is an individual resident of the State of Illinois. On April 28, 2008, <br /> Relator filed a qui tam action in the United States District Court for the Northern District of <br /> Illinois captioned United States of America ex rel. Jennifer D. Perez v. Stericycle, Inc., Case No. <br /> 1:08-ev-2390 (hereinafter referred to as the"Action"). <br /> C. On June 28, 2010, Relator filed an Amended Complaint adding the States of <br /> California, Delaware, Florida, Illinois, Indiana, Nevada,New Hampshire, New Jersey,New <br /> York,North Carolina, Rhode Island, Tennessee, the Commonwealths of Massachusetts and <br /> Virginia, and the District of Columbia (except for New Hampshire and New York, "Government <br /> Entities") as plaintiffs and alleging claims for relief under the respective state false claims law on <br /> behalf of state and local governmental agencies, as applicable. <br /> D. On July 23, 2013, Relator filed her Second Amended Complaint("SAC") in <br /> which she alleged claims on behalf of the Government Entities. The SAC dropped any claims on <br /> behalf of the State of New Hampshire. The SAC alleges Stericycle improperly increased its <br /> Page 1 of 10 <br />