SETTLEMENT AGREEMENT This Settlement Agreement (“Agreement
SETTLEMENT AGREEMENT This Settlement Agreement (“Agreement”) pertains to the resolution of the case titled, Jarboe, et al v. Maryland Department of Public Safety and Correctional Services (DPSCS), et al, U.S. District Court of Maryland Case No. 1:12-cv-00572-ELH, and is entered into between Christopher Jarboe, Carroll Connelly, Vander Davis, Gary Denmark, and Garfield Redd (collectively, “Plaintiffs”), and Maryland Department of Public Safety and Correctional Services (“DPSCS”), Maryland Division of Correction (“DOC”), Maryland Department of Labor, Licensing and Regulation, Division of Workforce Development and Adult Learning (Correctional Education) (“DLLR”), Maryland Correctional Enterprises, DPSCS Secretary Gary D. Maynard, Stephen T. Moyer (as substitute for Gary Maynard pursuant to Fed. R. Civ. Pro. 25), J. Michael Stouffer, Wayne Webb (as substitute for J. Michael Stouffer pursuant to Fed. R. Civ. Pro. 25), Paulette Francois, Julie Squire (as substitute for Paulette Francois pursuant to Fed. R. Civ. Pro. 25), James Rzepkowski (as substitute for Julie Squire pursuant to Fed. R. Civ. Pro. 25), and Stephen M. Shiloh, Maryland Correctional Institution- Jessup (“MCI-J”), Western Correctional Institution (“WCI”), Dayena Corcoran, Carroll Parrish (as substitute for Dayena Corcoran pursuant to Fed. R. Civ. Pro. 25), J. Phillip Morgan, and Richard J. Graham (as substitute for J. Phillip Morgan pursuant to Fed. R. Civ. Pro. 25) (collectively, “Defendants”). The foregoing individuals and entities are each referred to as a “Party” and collectively as the “Parties.” The Parties hereby stipulate and agree as follows: RECITALS WHEREAS, Plaintiffs are or were previously inmates in the custody of DPSCS who claim a disability by virtue of their being deaf and have filed a lawsuit against the Defendants in the United States District Court for the District of Maryland, styled Jarboe, et al.
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