Lyons v. IR Labs DE, LLC and SourceTek, Inc. — Confidential Settlement Agreement and Release (S.D. Iowa, Document 38-1)

Summary

A Confidential Settlement Agreement and Release, filed as Exhibit A, between named plaintiffs Chad Lyons and Christian Taveras and defendants IR Labs DE, LLC and SourceTek, Inc. in Case 4:24-cv-2-SHL-SBJ in the Southern District of Iowa. It follows a mediation on May 22, 2024 before the Honorable John A. Jarvey and sets a Global Settlement Fund of $440,138.76, including Service Awards of up to $4,000.00 and $298,000.00 for the IR Labs FLSA Settlement Group of 81 hourly employees; the other groups are 30 IR Labs WARN claimants and 29 SourceTek employees. Defendants deny all the claims and pay employer payroll taxes and administrator fees outside the fund, and attorneys' fees are addressed in a separate agreement. The agreement is contingent on approval by the Court.

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EXHIBIT A
Vinesign Document ID: AC5186C6-2503-4AAB-B304-9A49A0BB3360

CONFIDENTIAL SETTLEMENT AGREEMENT AND RELEASE
This Confidential Settlement Agreement and Release (the “Settlement Agreement”) is
entered into between Chad Lyons and Christian Taveras (the “Named Plaintiffs”), individually
and on behalf of others alleged to be similarly situated (collectively, “Plaintiffs”) on the one
hand, and IR Labs DE, LLC (“IR Labs”) and SourceTek, Inc. (“SourceTek”) (collectively,
“Defendants”) on the other hand (hereinafter, all together as the “Parties”), subject to the
approval of the Court.
RECITALS
WHEREAS, on January 2, 2024, Dakota Menaugh filed a Class and Collective Action
Complaint against IR Labs, and on January 26, 2024, the Named Plaintiffs filed an Amended
Class and Collective Action Complaint against IR Labs and SourceTek, which is pending as
Chad Lyons and Christian Taveras v. IR Labs DE, LLC and SourceTek, Inc., Case No. Case
4:24-cv-2-SHL-SBJ in the United States District Court for the Southern District of Iowa (the
“Lawsuit”). In the Lawsuit, Plaintiffs allege violations of the federal Worker Adjustment and
Retraining Notification Act, 29 U.S.C. § 2101 et seq. (“WARN”) and the Fair Labor Standards
Act, 29 U.S.C. § 201 et seq. (“FLSA”).

WHEREAS, on or about February 28, 2024, Dakota Menaugh filed an arbitration
demand alleging WARN and FLSA claims against IR Labs with JAMS (JAMS No.
5390000134), and the arbitration proceeding was subsequently closed on or about June 3, 2024
(“Menaugh Arbitration”);

WHEREAS, the Parties have engaged in extensive settlement negotiations, including an
all-day mediation session on May 22, 2024, presided over by an experienced third-party
mediator, the Honorable John A. Jarvey, which resulted in resolution of some claims, and
extensive negotiations over the course of the following months to resolve the remaining claims;

WHEREAS, there have been no determinations on the merits of the Lawsuit or the
Menaugh Arbitration, but the Parties desire to avoid additional cost and the uncertainty of
litigation and arbitration;

WHEREAS, the Parties and their counsel have interviewed witnesses, obtained and
reviewed documents, analyzed payroll data and other information, and analyzed and evaluated
the merits of the claims and defenses in the Lawsuit;

WHEREAS, based on Class Counsel’s analysis and evaluation of a number of factors,
and recognizing the substantial risks of litigation, including the possibility that these claims, if
not settled now, might not result in any recovery or might result in a recovery less favorable, and
that any recovery would not occur for several years, Class Counsel are satisfied that the terms
and conditions of this Settlement Agreement are fair, reasonable, and adequate and that this
Settlement Agreement is in the best interests of Plaintiffs;

The signed document can be validated at https://app.vinesign.com/Verify
WHEREAS, Defendants deny all the claims and contentions alleged by the Plaintiffs.
Nonetheless, Defendants have concluded that further litigation of the claims encompassed by the
Arbitration would be protracted and expensive and would also divert management and employee
time. Defendants also have taken into account the uncertainty and risks inherent in litigation and
have, therefore, concluded that it is desirable that the Lawsuit be settled in the manner and upon
the terms and conditions set forth in this Settlement Agreement; and

WHEREAS, the purpose of this Settlement Agreement is to settle fully and finally all
claims subject to the Releases that Plaintiffs may have against the Released Parties.

NOW, THEREFORE, in consideration of the mutual covenants and promises set forth in
this Settlement Agreement, as well as the good and valuable consideration provided for herein,
the parties hereto agree to a full and complete settlement on the following terms and conditions:

DEFINITIONS
1. The following terms used in this Settlement Agreement shall have the meanings ascribed
to them below:

a. “Class Counsel” is defined as William “Jack” Simpson of Simpson, PLLC and
Timm Reid of the Reid Law Firm, PLLC.

b. “Class Period” is defined as January 2, 2021, through the date of approval of
the Settlement Agreement by the Court.

c. The “Court” is defined as the United States District Court for the Southern
District of Iowa.

d. “Defendants’ Counsel” is defined as William Gignilliat of Jackson Lewis P.C.
and Randall D. Armentrout of Nyemaster Goode P.C. (“IR Labs’ Counsel”) and Angel
West of Maynard Nexsen P.C. (“SourceTek’s Counsel”).

e. “Effective Date” is defined as the first business day after the date on which the
Court approves this Settlement Agreement.

f. “Plaintiffs” is defined as the Named Plaintiffs and (1) the IR Labs FLSA
Settlement Group, (2) the IR Labs WARN Settlement Group, and (3) the SourceTek
Settlement Group, which are respectively defined as follows:

i. The “IR Labs FLSA Settlement Group” is defined as the 81 hourly
paid employees of IR Labs who were within scope of the pay data that was

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produced to Class Counsel prior to mediation on May 22, 2024. Exhibit A
contains the list of the IR Labs employee identification numbers of the 81 persons
who are in the IR Labs FLSA Settlement Group.

ii. The IR Labs WARN Settlement Group is defined as the 30 IR Labs
employees who were subject to a layoff in September 2023 and who retained
Class Counsel, as of September 23, 2024. Exhibit B contains the list of the 30
persons who are in the IR Labs WARN Settlement Group. Class Counsel must
provide IR Labs’ Counsel with proof of representation of each member of the IR
Labs WARN Settlement Group prior to execution of this Agreement.

iii. The SourceTek Settlement Group is defined as the 29 employees of
SourceTek that retained Class Counsel, as of September 13, 2024. Exhibit C
contains the list of the 29 persons who are in the SourceTek Settlement Group.
Class Counsel must provide proof of representation of each member of the
SourceTek Settlement Group prior to execution of this Agreement.

g. The “Settlement Administrator” is defined as a third-party settlement claims
administrator selected by IR Labs, with such selection subject to approval by the other
Parties (and such approval shall not be unreasonably withheld), to aid in the administration
of the Settlement Agreement.

MUTUAL COOPERATION

2. The Parties and their counsel shall cooperate with each other and use their best efforts
as reasonably necessary and appropriate to obtain Court approval of this Settlement Agreement
and to implement the terms of the Settlement Agreement.

SETTLEMENT APPROVAL

3. Settlement Approval Process. The Parties agree to the following procedures for
obtaining approval of the Settlement Agreement by the Court:

a. Within three (3) calendar days of execution of this Settlement Agreement, the
Parties will informally notify the Court via email that the parties have entered into a
Settlement Agreement and plan to prepare and file a Joint Motion for Settlement Approval.

b. Within twenty-one (21) calendar days of execution of this Settlement
Agreement, the Parties will jointly prepare and file a Joint Motion for Settlement Approval,
a proposed order approving the terms and conditions of this Settlement Agreement,
dismissing all claims subject to the Releases with prejudice, and dismissing the Lawsuit.

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c. The Parties shall cooperate and present to the Court such information as may be
reasonably requested for consideration in connection with approving the Settlement
Agreement.

4. Nullification of Settlement Agreement. This Settlement Agreement is contingent on
approval by the Court. In the event that the Court does not approve the Settlement Agreement
in whole or in part, then this Settlement Agreement shall be null and void and the Parties shall
be returned to their respective statuses as of the date immediately prior to the execution of this
Settlement Agreement. If this occurs, the Parties shall proceed in all respects as if the
Settlement Agreement had not been executed. However, nothing in this provision prevents the
Parties from conferring and attempting in good faith to address any concerns raised by the
Court and submitting a revised settlement agreement for approval.

RESPONSIBILITIES OF THE SETTLEMENT ADMINISTRATOR

5. Administration of Settlement. Class Counsel and Defendants’ Counsel agree to
cooperate and engage with a Settlement Administrator to administer and implement designated
aspects of this Settlement Agreement. The designated duties of the Settlement Administrator are
defined below, and the Parties will include them in the engagement agreement with the
Settlement Administrator. Subject to the terms and conditions of this Agreement, the
Settlement Administrator shall be responsible for:

a. Establishing the Global Settlement Fund as a “Qualified Settlement Fund” within
the meaning of Section 468B of the Internal Revenue Code of 1986, as amended, the Treas.
Reg. Section 1.468B-1, et seq.;
b. Determining and finalizing the amount of each Plaintiff’s settlement payment(s)
and the tax withholding amounts and employer payroll tax amounts, as applicable;
c. Preparing, printing, and disseminating the Notice of Settlement and Claim Form
to all eligible members of the IR Labs FLSA Settlement Group;
d. Processing and maintaining a record of all eligible members of the IR Labs FLSA
Settlement Group that submit a Claim Form and reporting that information to Class Counsel
and IR Labs’ Counsel;
e. Promptly apprising the Parties’ Counsel of the activities of the Settlement
Administrator, timely responding to inquiries of the Parties or their Counsel, and copying the
Parties’ Counsel on material correspondence;
f. Printing and mailing settlement payment checks to eligible Plaintiffs;

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g. Issuing IRS Forms W-2, 1099, and W-9 (if required), as well as any mandatory
state tax forms, for payments to each Plaintiff;
h. Promptly notifying the Parties’ Counsel of any material requests or
communications made by eligible Plaintiffs that the Settlement Administrator cannot resolve
and/or which involve matters not within the Settlement Administrator’s duties specified in
this Agreement;
i. Maintaining adequate records of its activities, including the date of the mailing of
the Notices of Settlement, the date of receipt of Claim Forms, receipt of returned mail, and
other communications and attempted communications with Plaintiffs, and providing the
Parties’ Counsel with weekly reports regarding the same;
j. Confirming, in writing to the Parties’ Counsel its completion of the administration
of this Settlement Agreement and retaining copies of all endorsed settlement checks;
k. Performing any other duties expressly identified in this Settlement Agreement;
and
l. Such other tasks as customarily and regularly performed by a settlement
administrator and as the Parties mutually agree.

SETTLEMENT FUNDS AND ALLOCATIONS

6. Global Settlement Fund.

a. Defendants will establish a “Global Settlement Fund” of Four Hundred and
Forty Thousand, One Hundred and Thirty-Eight Dollars and Seventy-Six Cents
($440,138.76), which is the maximum amount Defendants can be required to pay under this
Settlement Agreement and the maximum amount necessary to fully resolve Plaintiffs’
claims. Payments from the Global Settlement Fund will cover all of the wage and non-
wage payments to Plaintiffs, as well as withholdings for the employee’s share of payroll
taxes on the wage portion of the payments to Plaintiffs, for all of the following: (1) the
Service Awards to the Named Plaintiffs, (2) the Settlement Fund for the IR Labs FLSA
Settlement Group, (3) the Settlement Fund for the IR Labs WARN Settlement Group, and
(4) the Settlement Fund for the SourceTek Settlement Group.

b. Notwithstanding the above, Defendants will remain responsible for paying the
employer’s share of payroll taxes on the wage portion of the payments to Plaintiffs, and
such amounts are neither included in nor shall be deducted from the Global Settlement
Fund. Likewise, Defendants will remain responsible for paying the Settlement
Administrator’s fees and expenses (subject to a separate agreement with the Settlement

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Administrator), and such fees and expenses are neither included in nor shall be deducted
from the Global Settlement Fund. The Global Settlement Fund does not include any
payment for Class Counsel’s attorneys’ fees and costs under the FLSA, which are
addressed below in Sections 32-35 and in the Supplemental Confidential Settlement
Agreement and Release on Attorneys’ Fees and Costs.

c. The amount of contribution into the Global Settlement Fund by each Defendant
will be determined in the sole discretion of Defendants and is subject to a separate,
confidential agreement between Defendants.

d. The Global Settlement Fund will be established as a “Qualified Settlement Fund”
within the meaning of Section 468B of the Internal Revenue Code of 1986, as amended, the
Treas. Reg. Section 1.468B-1, et seq., and shall be administered by the Settlement
Administrator, subject to the ultimate authority of the Court. The Settlement Administrator
shall serve as Trustee of the Global Settlement Fund and shall act as a fiduciary with respect
to the handling, management, and distribution of the Global Settlement Fund, including the
handling of tax-related issues, reporting requirements, and payments. The Settlement
Administrator shall act in a manner necessary to qualify the Global Settlement Fund as a
Qualified Settlement Fund and to maintain that qualification. The Parties shall cooperate to
ensure such treatment and shall not take a position in any filing or before any tax authority
inconsistent with such treatment.

e. From the Global Settlement Fund, settlement funds shall be allocated among
Plaintiffs as set forth in Sections 7-12 of this Settlement Agreement.

7. Service Awards. Class Counsel will seek approval from the Court for payment of
Service Awards to compensate the Named Plaintiffs, for their role as representatives, in a total
amount not to exceed Four Thousand Dollars and Zero Cents ($4,000.00), to be distributed
from the Global Settlement Fund. From that total amount for Services Awards, Two Thousand
Dollars and Zero Cents ($2,000.00) will be allocated to each of the two Named Plaintiffs.
Defendants agree not to oppose the Service Awards up to the agreed amounts. If the Court
awards a lesser amount for Service Awards, Defendants shall pay the lesser amount approved
by the Court, and the provisions and Releases in this Settlement Agreement shall continue to
be fully effective. Any amount requested but not approved shall be re-allocated into the
Settlement Fund for the IR Labs FLSA Settlement Group (50%) and the Settlement Fund for
the SourceTek Settlement Group (50%). For example, if the Court Awards only $3,000 in
Service Awards and the remaining $1,000 is not approved for Service Awards, then the
Settlement Fund for the IR Labs FLSA Settlement Group and the Settlement Fund for the
SourceTek Settlement Group would each be increased by $500.00. The Service Awards shall
be reported on IRS Form 1099. The Settlement Administrator shall be instructed to provide the

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Named Plaintiffs an IRS Form 1099 (and any corresponding state form) for any Service Awards
received. Each Named Plaintiff shall be solely and legally responsible to pay any and all
applicable taxes on the payment made to him/her as a Service Award.

8. Settlement Fund for the IR Labs FLSA Settlement Group. From the Global
Settlement Fund, the Settlement Administrator shall allocate Two Hundred and Ninety-Eight
Thousand Dollars and Zero Cents ($298,000.00), which is the “Settlement Fund for the IR
Labs FLSA Settlement Group.” The Settlement Fund for the IR Labs FLSA Settlement Group
is the maximum amount Defendants can be required to pay to the IR Labs FLSA Settlement
Group under this Settlement Agreement and the maximum amount necessary to fully resolve
the claims of the IR Labs FLSA Settlement Group, as set forth in the Releases.

a. Allocations from the Settlement Fund for the IR Labs FLSA Settlement
Group. Subject to the terms and conditions of this Agreement, the Settlement Administrator
will allocate a portion of the Settlement Fund for the IR Labs FLSA Settlement Group to
each individual member of the IR Labs FLSA Settlement Group, according to a calculation
described herein. Allocations of settlement payments to the IR Labs FLSA Settlement Group
will be determined based on the number of qualifying weeks worked by members of the IR
Labs FLSA Settlement Group during the Class Period. The number of qualifying weeks
worked by each individual member of the IR Labs FLSA Settlement Group during the Class
Period will be determined by reference to IR Labs’ records, which will be provided to
Settlement Administrator and will be presumed to be correct. The Settlement Administrator
will calculate the total number of qualifying weeks worked by all members of the IR Labs
FLSA Settlement Group during the Class Period. The Settlement Administrator shall assign
to each member of the IR Labs FLSA Settlement Group a “FLSA Settlement Ratio” which
shall be a fractional number comprised of: (a) that individual member’s total number of
qualifying weeks worked during the Class Period as the numerator, and (b) the aggregate
total of qualifying weeks worked by all members of the IR Labs FLSA Settlement Group
during the Class Period as the denominator. The Settlement Administrator shall then assign
to each member of the IR Labs FLSA Settlement Group a “FLSA Settlement Award”
which shall be calculated by multiplying that member’s FLSA Settlement Ratio by the total
amount allocated to the Settlement Fund for the IR Labs FLSA Settlement Group. Prior to
distributing any payments, the Settlement Administrator shall provide the proposed FLSA
Settlement Awards and supporting calculations to Class Counsel and IR Labs’ Counsel for
their review and approval (and their approval shall not be unreasonably withheld). Members
of the IR Labs FLSA Settlement Group will only receive payment of their FLSA Settlement
Award if they timely submit a valid Claim Form in accordance with Sections 14-20.
Members of the IR Labs FLSA Settlement Group who do not submit a Claim Form will not
be paid a FLSA Settlement Award. Any sums not payable from the Settlement Fund for the
IR Labs FLSA Settlement Group (i.e., the FLSA Settlement Awards allocated to members of

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the IR Labs FLSA Settlement Group who fail to timely submit a valid Claim Form) shall not
be payable by Defendants and shall be retained by IR Labs.

9. Settlement Fund for the IR Labs WARN Settlement Group. From the Global
Settlement Fund, the Settlement Administrator shall allocate Thirty Thousand, One Hundred
and Thirty-Eight Dollars and Seventy-Six Cents ($30,138.76), which is the maximum
amount Defendants can be required to pay to the IR Labs WARN Settlement Group under this
Settlement Agreement and the maximum amount necessary to fully resolve the claims of the
IR Labs WARN Settlement Group, as set forth in the Releases.

a. Allocations from the Settlement Fund for the IR Labs WARN Settlement
Group. Subject to the terms and conditions of this Agreement, the Settlement Administrator
will allocate a “WARN Settlement Award” from the Settlement Fund for the IR Labs
WARN Settlement Group to each individual member of the IR Labs WARN Group, as
follows: (1) John Dauber shall be allocated Ten Thousand Dollars and Zero Cents
($10,000.00); and (2) the other 29 members of the IR Labs FLSA WARN Group shall each
be allocated Six Hundred and Ninety Four Dollars and Forty-Four Cents ($694.44).

10. Settlement Fund for the SourceTek Settlement Group. From the Global Settlement
Fund, the Settlement Administrator shall allocate One Hundred and Eight Thousand Dollars
and Zero Cents ($108,000.00), which is the maximum amount Defendants can be required to
pay to the SourceTek Settlement Group under this Settlement Agreement and the maximum
amount necessary to fully resolve the claims of the SourceTek Settlement Group, as set forth in
the Releases.
a. Allocations from the Settlement Fund for the SourceTek Settlement Group.
Subject to the terms and conditions of this Agreement, the Settlement Administrator will
allocate a “SourceTek Settlement Award” from the Settlement Fund for the SourceTek
Settlement Group to each individual member of the SourceTek Settlement Group, in equal
shares as follows: the 29 members of the SourceTek Settlement Group shall each be
allocated Three Thousand, Seven Hundred and Twenty-Four Dollars and Fourteen
Cents ($3,724.14).

11. Individual Settlement Awards. Some Plaintiffs may be members of multiple
Settlement Groups. For example, some Plaintiffs may be members of both the IR Labs FLSA
Settlement Group and the IR Labs WARN Settlement Group and thus would be eligible for
both a FLSA Settlement Award and WARN Settlement Award. Some Plaintiffs are only a
member of a single Settlement Group and are only eligible for an allocated Settlement Award
from the applicable Settlement Group. Each Plaintiff’s “Individual Settlement Award” shall
be calculated as the sum of his or her allocated FLSA Settlement Award (contingent on timely
submission of a valid Claim Form), WARN Settlement Award, and/or SourceTek Settlement

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Award, as applicable.

12. Tax Treatment of Individual Settlement Awards. Of the allocated Individual
Settlement Award applicable to each Plaintiff, fifty percent (50%) shall be treated as payment
for allegedly unpaid wages and this portion shall be reported on IRS Form W-2. The wage
portion will be subject to withholdings and deductions for applicable federal and state income
and employment taxes, which will be paid from the Global Settlement Fund. The other fifty
percent (50%) of the allocated Individual Settlement Award applicable to each Plaintiff shall
be treated as payment for alleged non-wage penalties and liquidated damages, to be reported
on IRS Form 1099, and shall not be subject to withholdings. Within the time period prescribed
by applicable law, the Parties shall instruct the Settlement Administrator to provide to each
Plaintiff receiving a settlement payment an IRS Form W-2 (for the wage portion) and an IRS
Form 1099 (for the non-wage portion), and any corresponding state tax reporting forms. Each
Plaintiff shall be solely and legally responsible to pay any and all applicable taxes on their
respective portions of their Individual Settlement Awards.

13. Prior to distributing any payments, the Settlement Administrator shall provide the
proposed Individual Settlement Awards and supporting calculations to Defendants’ Counsel and
Class Counsel for their review and approval (and their approval shall not be unreasonably
withheld). Subject to review and approval by the Parties’ Counsel and contingent upon the
Court’s approval of this Settlement Agreement, the Settlement Administrator will distribute a
payment of the allocated Individual Settlement Award to each Plaintiff in accordance with
Sections 14-31.

NOTICE AND CLAIM PROCEDURES FOR IR LABS FLSA SETTLEMENT GROUP

14. “Notice of Settlement” is defined as the form approved by Class Counsel and IR Labs’
Counsel, and subject to Court approval, that will be sent to each member of the IR Labs FLSA
Settlement Group and which will explain relevant terms of this Settlement Agreement and the
claims process to receive a FLSA Settlement Award. A copy of the Notice of Settlement is
attached as Exhibit D.

15. “Claim Form” is defined as the form approved by Class Counsel and IR Labs’ Counsel,
and subject to Court approval, that each member of the IR Labs FLSA Settlement Group must
sign, complete in full, and timely submit to receive a FLSA Settlement Award. A copy of the
Claim Form is attached as Exhibit E. On each Claim Form, the Settlement Administrator shall
print an identification number that is unique to the designated recipient member of the IR Labs
FLSA Settlement Group.

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16. Within seven (7) days of the Effective Date, IR Labs shall provide the Settlement
Administrator with an Excel spreadsheet for the IR Labs FLSA Settlement Group, which will
list their names, employee ID numbers, social security numbers, last known addresses, work
location state, and dates of employment during the Class Period, as that information exists in IR
Lab’s records. This spreadsheet shall not be provided to Class Counsel or Plaintiffs, and the
Settlement Administrator shall not disclose names and contact information of members of the
FLSA Settlement Group to Class Counsel, except for those who timely submit Claim Forms.

17. Within fourteen (14) days of the Effective Date, the Settlement Administrator shall mail
a Notice of Settlement and a Claim Form to each member of the IR Labs FLSA Settlement
Group. The Settlement Administrator shall notify Defendants’ Counsel and Class Counsel of
the actual date that the Notices and Claim Forms are initially mailed to Plaintiffs, which is the
“Mailing Date.” If any Notice of Settlement is returned as undeliverable, the Settlement
Administrator will promptly attempt to identify a correct address for such Plaintiff through
reasonable and legally acceptable means, and, if identified, shall promptly mail an additional
Notice of Settlement and Claim Form to such Plaintiff.

18. Each member of the IR Labs FLSA Settlement Group shall have forty-five (45) days
from the Mailing Date to complete, personally sign, and submit his or her Claim Form, and any
such submission must be received by the Settlement Administrator on, or before, the forty-fifth
(45th) day from Mailing Date (“Claim Deadline”). To be valid, the Claim Form must be fully
completed, personally signed, show the correct unique identification number printed by the
Settlement Administrator, and be received by the Settlement Administrator by the Claim
Deadline.

19. Within seven (7) days of the Claim Deadline, the Settlement Administrator will provide
Class Counsel and IR Labs’ Counsel with a list of all members of the IR Labs FLSA Settlement
Group who timely submitted Claim Forms, as well as copies of the submitted Claim Forms.

20. Members of the IR Labs FLSA Settlement Group will only receive payment of their
FLSA Settlement Award if they timely submit a valid Claim Form in accordance with these
procedures. Members of the IR Labs FLSA Settlement Group who do not timely submit a valid
Claim Form will not be paid a FLSA Settlement Award.

SETTLEMENT ADMINISTRATION AND PAYMENT
21. Within seven (7) days of the Effective Date, Defendants shall provide the Settlement
Administrator and Class Counsel with an Excel spreadsheet for each of the following groups of
Plaintiffs: (1) the IR Labs WARN Settlement Group, and (2) the SourceTek Settlement Group.
Each such spreadsheet will list the names, employee ID numbers, social security numbers, last
known addresses, work location state, and dates of employment during the Class Period, as that
information exists in Defendants’ records. If Class Counsel intends to submit any corrections or

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updated information as to any names (e.g., due to marriage), address information, or dates of
employment, Class Counsel shall submit such information to Defendants’ Counsel for review
and approval within fourteen (14 days) of the Effective Date. Subject to Defendants’ review and
approval (which shall not be unreasonably withheld), such corrections and updated information
shall be submitted to the Settlement Administrator within twenty-one (21) days of the Effective
Date.

22. Within fourteen (14) days of the Effective Date, the Settlement Administrator shall open
an interest-bearing bank account, which will hold the Global Settlement Fund, and provide
instructions to Defendants’ Counsel for transferring settlement funds into the account.

23. Within thirty (30) days of the Effective Date (the “Funding Date”), Defendants shall
deposit funds totaling Four Hundred and Forty Thousand, One Hundred and Thirty Eight
Dollars and Seventy-Six Cents ($440,138.76) into the account designated for holding the
Global Settlement Fund.

24. All payments from the account holding the Global Settlement Fund are contingent on
approval of this Settlement Agreement by the Court. The Settlement Administrator will be
responsible for distribution of checks for Individual Settlement Awards to each Plaintiff.

25. Within seven (7) days of the Claim Deadline (which is expected to occur after the
Funding Date), the Settlement Administrator shall: (1) calculate the following: (a) the FLSA
Settlement Award applicable to each member of the IR Labs FLSA Settlement Group who
timely submitted a valid Claim Form, (b) the FLSA Settlement Award applicable to each
member of the IR Labs FLSA Settlement Group who failed to timely submitted a valid Claim
Form, (c) the WARN Settlement Award applicable to each member of the IR Labs WARN
Settlement Group, (d) the SourceTek Settlement Award applicable to each member of the
SourceTek Settlement Group, (e) the Individual Settlement Award applicable to each Plaintiff
(excluding any unclaimed FLSA Settlement Awards), and (f) the Defendants’ required employer
share of payroll taxes with respect to any portions of the Individual Settlement Awards treated as
wages (again, excluding any unclaimed FLSA Settlement Awards); and (2) provide the above
information with supporting calculations to Class Counsel and Defendants’ Counsel for review
and approval.

26. Within twenty-one (21) days of the Claim Deadline, Class Counsel and Defendants’
Counsel shall review the proposed Settlement Awards and supporting calculations provided by
the Settlement Administrator and either approve them or identify concerns and address them
with the Settlement Administrator and the other Parties’ Counsel. Such approval shall not be
unreasonably withheld.

27. Within twenty-one (28) days of the Claim Deadline, the Settlement Administrator shall
transfer to IR Labs any portion of the Global Settlement Fund that had been allocated to FLSA

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Settlement Awards of members of the IR Labs FLSA Settlement Group who failed to timely
submit a valid Claim Form.

28. Within twenty-one (28) days of the Claim Deadline, Defendants shall transfer to the
Settlement Administrator any additional funds needed to cover Defendants’ required employer
share of payroll taxes with respect to any portions of the Individual Settlement Awards treated as
wages. Such funds will be separate from the Global Settlement Fund but will also be deposited
by the Claims Administrator into an interest-bearing account.

29. Subject to the Parties’ Counsel’s approval of the Settlement Administrator’s calculations
and subject to all other terms and conditions of this Agreement, within thirty-five (35) days of
the Claim Deadline, the Settlement Administrator shall mail a payment of the allocated
Individual Settlement Award to each Plaintiff. If possible, the Settlement Administrator will
issue each Plaintiff one single check representing the total amount of his or her Individual
Settlement Award by combining the wage and non-wage portions of his or her Individual
Settlement Award, subject to any withholdings for the employee’s share of payroll taxes on the
wage portion. On the same date, the Settlement Administrator shall mail a payment of the
Service Awards to the Named Plaintiffs. The Settlement Administrator shall notify Defendants’
Counsel and Class Counsel of the actual date that the Individual Settlement Award checks and
Service Award checks are mailed to Plaintiffs, which is the “Payment Date.”

30. To the extent that any Plaintiff fails to deposit his or her settlement check(s) within
sixty (60) days of the Payment Date, then the Settlement Administrator shall issue a stop-
payment order on such checks.

31. Within seventy (70) days of the Payment Date, the Settlement Administrator shall
transfer to IR Labs any remaining or unclaimed portions of the Global Settlement Fund, as well
as any interest that has accrued in the account(s) established by the Settlement Administrator
under this Settlement Agreement.

CLASS COUNSEL’S ATTORNEYS’ FEES AND COSTS

32. After agreeing to the principal terms of this Settlement Agreement, the Parties
separately negotiated and resolved the issue of Class Counsel’s reasonable fees and costs. The
terms for resolving Class Counsel’s fees and costs are set forth in the Supplemental
Confidential Settlement Agreement and Release on Attorneys’ Fees and Costs.

33. The enforceability of this Settlement Agreement is not contingent on any separate
settlement on the issue of Class Counsel’s fees and costs. The enforceability of the Settlement
Agreement is not contingent on whether Court awards the amount sought by Class Counsel for
fees and costs or a lesser amount. If the Court awards a lesser amount in fees and costs,
Defendants shall pay the lesser amount approved by the Court, and the provisions and Releases

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in this Settlement Agreement shall continue to be fully effective. Any amount requested but
not approved by the Court shall be retained by Defendants.

34. Defendants shall have no responsibility for allocating or distributing attorneys’ fees and
costs among Class Counsel. The Released Parties shall be indemnified and held harmless from
any disputes or claims regarding allocation of fees and costs among Class Counsel.

35. Any payment for Class Counsel’s fees and costs shall be reported on IRS Form 1099,
which shall be issued to Class Counsel.

RELEASES
36. Releases. In consideration of the benefits to be received by Plaintiffs under this
Settlement Agreement, upon the Effective Date, the Parties agree as follows:

a. All members of the IR Labs FLSA Settlement Group who timely submit a
Claim Form and their executors, administrators, successors, and assigns, shall release,
waive, and forever discharge the Released Parties (as defined below) from all Wage-
and-Hour Claims (as defined below).

i. Members of the IR Labs FLSA Settlement Group who do not timely submit a
Claim Form are not subject to the above Release provision and will not
receive any FLSA Settlement Award. However, they may be subject to the
below Release provisions, if applicable.

b. All members of the IR Labs WARN Settlement Group and their executors,
administrators, successors, and assigns, shall release, waive, and forever discharge the
Released Parties (as defined below) from all Wage-and-Hour Claims (as defined
below) and all Employment Claims (as defined below).

c. All members of the Sourcetek Settlement Group and their executors,
administrators, successors, and assigns, shall release, waive, and forever discharge the
Released Parties (as defined below) from all Wage-and-Hour Claims (as defined
below) and all Employment Claims (as defined below).

d. “Released Parties” means all Defendants (IR Labs DE, LLC and SourceTek,
Inc.) and their direct and indirect parents, affiliates, subsidiaries, divisions, owners,
shareholders, partners, joint venturers, professional employment organizations,
representatives, predecessors, successors, assigns, clients, and customers, and all of their
current and former employees, officers, directors, attorneys, insurers, and agents thereof,
both individually and in their business capacities, and their employee benefit plans and
programs and their plan administrators and fiduciaries.

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e. “Wage-and-Hour Claims” means any and all state, local, or federal claims,
obligations, demands, actions, rights, causes of action and liabilities, whether known or
unknown, against the Released Parties for alleged unpaid wages, overtime damages,
minimum wages, unreimbursed expenses, inadequate meal or rest breaks, inadequate pay
statements, penalties (including late payment and waiting-time penalties), premium pay,
interest, liquidated or other damages, restitution, attorneys’ fees, costs, expenses, and any
other compensation and relief under the Fair Labor Standards Act (“FLSA”) and any other
federal, state, and local wage-related law (including statutory, common law, contractual,
and equitable claims) that arise from or relate to Plaintiffs’ employment or association with
the Released Parties during the Class Period.

f. “Employment Claims” means all claims and causes of action of whatever
nature, known and unknown, asserted or unasserted, against the Released Parties that arise
from or relate to Plaintiffs’ employment or association with the Released Parties during the
Class Period, including, but not limited to, any alleged violation of the following, as
amended: the Worker Adjustment and Retraining Notification Act; Title VII of the Civil
Rights Act of 1964; Americans with Disabilities Act of 1990; Fair Credit Reporting Act;
Family and Medical Leave Act; Equal Pay Act; Sections 1981 through 1988 of Title 42 of
the United States Code; Employee Retirement Income Security Act of 1974 (“ERISA”);
Internal Revenue Code of 1986; Immigration Reform and Control Act; Genetic Information
Nondiscrimination Act of 2008; Uniformed Services Employment and Reemployment
Rights Act of 1994 (“USERRA”); Families First Coronavirus Response Act; any other
federal, state or local law, rule, regulation, or ordinance; any public policy, contract, tort
law, or common law; or any basis for recovering costs, fees, or other expenses including
attorneys’ fees incurred in such matters.

g. The Releases set forth above cover and release any claims for Class Counsel’s
attorneys’ fees and costs, as set forth in the Supplemental Confidential Settlement Agreement
and Release on Attorneys’ Fees and Costs.

h. No Plaintiff or other person shall have any claim against the Released Parties
based on allocations, calculations, distributions, or payments made in accordance with this
Settlement Agreement. The Released Parties shall be indemnified and held harmless from
any disputes, claims, or errors relating to the allocation, calculation, distribution, and
payment of settlement funds to Plaintiffs.

i. Tax Indemnification. Plaintiffs agree to pay any taxes found to be owed from
settlement payments made pursuant to this Settlement Agreement and to hold the Released
Parties harmless from any claims, assessments, demands, penalties and interest found to be

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owed as a result of any payment made pursuant to this Settlement Agreement.

MISCELLANEOUS

37. Denial of Wrongdoing; No Admission of Fault. Defendants enter into this Agreement
to avoid further expense and disruption to their businesses. Defendants contend that Plaintiffs
have been compensated in full compliance with the law. Defendants contend that they have
acted in full compliance with WARN. Defendants have denied and continue to deny the claims
and contentions alleged by Plaintiffs in the Lawsuit. Defendants deny any wrongdoing or legal
liability arising out of any of the facts or conduct alleged and believe they have valid defenses
to Plaintiffs’ claims. Neither this Settlement Agreement, nor any document referred to or
contemplated herein, nor any action taken to carry out this Settlement Agreement, may be
construed as, or may be used as an admission, concession, or indication by or against the
Released Parties of any fault, wrongdoing or liability whatsoever, or of any concession that
certification of a collective action would be appropriate.

38. Inadmissibility of Settlement Agreement. Except for purposes of settling this matter
or enforcing the Settlement Agreement, neither this Settlement Agreement, nor its terms, nor
any document, statement, proceeding or conduct related to this Settlement Agreement, nor any
reports or accounts thereof, shall be construed as, offered or admitted in evidence as, received
as, or deemed to be evidence for any purpose adverse to the Released Parties, including,
without limitation, evidence of a presumption, concession, indication or admission by any of
the Parties of any liability, fault, wrongdoing, omission, concession or damage.

39. Computation of Time. For purposes of this Settlement Agreement, if the prescribed
time period in which to complete any required or permitted action expires on a Saturday,
Sunday, or legal holiday (as defined by FED. R. CIV. P. 6(a)(6)), such time period shall be
continued to the following business day.

40. Cooperation and Drafting. The Parties have cooperated in the drafting and
preparation of this Settlement Agreement; hence the drafting of this Settlement Agreement
shall not be construed against any of the Parties. The Parties agree that the terms and
conditions of this Settlement Agreement were negotiated at arms’ length and in good faith by
the Parties and reflect a settlement that was reached voluntarily based upon adequate
information and sufficient investigation and after consultation with experienced legal counsel.

41. Confidentiality of Material Provided to Class Counsel and the Settlement
Administrator. All materials provided by Defendants to Class Counsel or the Settlement
Administrator shall be kept confidential and used for the sole purpose of implementing the
Settlement Agreement.

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42. Limited Notice of Settlement; Non-Publicity.

a. Subject to Court approval, the only notice of settlement permitted by this
Agreement is the court-authorized Notice of Settlement that the Settlement Administrator
will mail to members of the IR Labs FLSA Settlement Group pursuant to Section 17 of this
Agreement.

b. Plaintiffs and Class Counsel shall not directly or indirectly provide any
notification regarding the terms or existence of this Settlement Agreement to other current
or former employees of SourceTek who are not part of the SourceTek Settlement Group.

c. Plaintiffs and Class Counsel shall not directly or indirectly provide any
notification regarding the terms or existence of this Settlement Agreement to other current
or former employees of IR Labs who are not part of the IR Labs WARN Settlement Group.

d. Class Counsel may continue to provide advice to current or former employees of
SourceTek and IR Labs who have already retained Class Counsel (i.e. the IR Labs WARN
Settlement Group and the SourceTek Settlement Group). Further, Class Counsel may
provide advice to employees of SourceTek and IR Labs who retain Class Counsel in the
future, though Class Counsel will not engage in any publicity, marketing or solicitation
efforts targeting current or former employees of SourceTek and IR Labs.

e. A copy of the Settlement Agreement may be filed on the Court’s docket, if
necessary to obtain Court approval. Otherwise, Plaintiffs agree that this Settlement
Agreement shall be treated as confidential and that all documents related to the Settlement
Agreement shall also be confidential, except as required by law or as expressly permitted
herein. Plaintiffs and Class Counsel shall not, directly or indirectly, publicize, disclose,
divulge, communicate, or otherwise reveal or allow to be revealed (a) the terms, substance, or
content of this Settlement Agreement or (b) the terms, substance, or content of any
communications, written or oral, concerning the negotiation, execution or implementation of
this Settlement Agreement to any person, entity or in any medium, including, but not limited
to, any television station, radio station, newspaper, internet site, social media, web, magazine,
journal, report, pamphlet, book, news/press release, billboard, public posting, or any other
media outlet, except as required by law or as specified herein. Plaintiffs and Class Counsel
agree not to hold any press conference, speak to the media, or engage in any press publicity,
advertising, or solicitation (including online solicitation) of any type related to the existence,
terms, negotiation, or implementation of this Settlement Agreement. If Class Counsel
receives an inquiry about settlement from the media, Class Counsel shall decline to
comment. Notwithstanding the above, the Settlement Agreement shall not be construed to
limit the rights of Plaintiffs under the National Labor Relations Act, and nothing in this

16
Agreement prohibits Plaintiffs from testifying under subpoena, Court order, or other
compulsory legal process. Further, the Parties may disclose information regarding the
existence or substance of this Agreement to their spouse, tax advisor, counsel, and/or to the
extent required by any federal, state or local government agency. To the extent Plaintiffs
reveal information to their spouse, tax advisor, or counsel as permitted by this Section, they
agree to inform those persons of the non-publicity and confidentiality requirements contained
herein and instruct them to comply with such requirements.

43. Class Counsel’s Affirmation. Class Counsel affirm that they do not have any claims
“in queue” or ready to file against Defendants by current or former employees of SourceTek or
IR Labs (except for the members of IR Labs WARN Settlement Group and SourceTek
Settlement Group, whose claims shall be resolved by this Settlement Agreement).

44. Jurisdiction of the Court. If the Settlement Agreement is approved by the Court, any
dispute arising out of this Settlement Agreement, or relating to the Releases, shall be subject to
the exclusive jurisdiction of the Court. Plaintiffs and Defendants agree to submit to the
exclusive jurisdiction of the Court to resolve such disputes. If the Settlement Agreement is
approved by the Court, the Court shall retain jurisdiction with respect to the interpretation,
implementation, validity, and enforcement of the terms of this Settlement Agreement and all
orders and judgments entered in connection therewith.

45. Bona Fide Dispute; Enforceability. Plaintiffs agree, warrant, and acknowledge that
there are bona fide legal arguments and disputes between Plaintiffs and Defendants, and that
the consideration provided herein reflects a full compromise for any such claims, including
claims under the FLSA and applicable state or local wage law, during the Class Period. The
Parties agree that this Settlement Agreement is fully enforceable and binding on the Parties
upon approval of the Court.

46. Amendment or Modification. This Settlement Agreement may be amended or
modified only by a written instrument signed by the Parties and their counsel.

47. Entire Settlement Agreement. This Settlement Agreement - in conjunction with the
attached Exhibits, and with the “Supplemental Confidential Settlement Agreement and Release
on Attorneys’ Fees and Costs” entered between the Parties and the “Settlement Contribution
and Mutual Release Agreement” entered between IR Labs and SourceTek - constitutes the
entire agreement among the Parties, and no oral or written representations, warranties or
inducements have been made to any party concerning this Settlement Agreement other than the
representations, warranties, and covenants contained and memorialized in such documents. All
prior or contemporaneous negotiations, memoranda, agreements, understandings, and
representations, whether written or oral, are expressly superseded hereby and are of no further
force and effect. Each of the Parties acknowledges that they have not relied on any promise,

17
representation or warranty, express or implied, not contained in this Settlement Agreement.
This Settlement Agreement does not supersede or replace any existing arbitration agreements,
confidentiality agreements, or restrictive covenant agreements between any Plaintiffs and any
Defendants; such agreements will survive and remain in full force and effect, regardless of
whether or not this Settlement Agreement is approved by the Court.

48. Binding on Successors and Assigns. This Settlement Agreement shall be binding
upon, and inure to the benefit of, the Plaintiffs and the Released Parties, and their heirs,
beneficiaries, executors, administrators, successors, transferees, assigns, or any corporation or
any entity with which any party may merge, consolidate, or reorganize.

49. Controlling Law. This Settlement Agreement shall be subject to, governed by,
construed, enforced, and administered in accordance with the laws of the State of Iowa,
without regard for the principle of conflict of laws.

50. Authorization to Enter into Settlement Agreement. Counsel for all Parties are
expressly authorized by the Parties whom they represent to enter into this Settlement
Agreement and to take all appropriate action required or permitted to be taken by such Parties
pursuant to this Settlement Agreement to effectuate its terms, and to execute any other
documents required to effectuate the terms of this Settlement Agreement.

51. Counterparts. This Settlement Agreement may be executed in one or more
counterparts, including by facsimile or email. All executed counterparts and each of them shall
be deemed to be one and the same instrument.

IN WITNESS WHEREOF, the Parties and their counsel have agreed to and executed this
Settlement Agreement as follows:

NAMED PLAINTIFFS:

_______________________________ 02/10/2025
Date: __________________
Chad Lyons

_______________________________ Date: __________________
Christian Taveras

CLASS COUNSEL:

________________________________ Date: __________________
Jack Simpson
Simpson, PLLC

18
representation or warranty, express or implied, not contained in this Settlement Agreement.
This Settlement Agreement does not supersede or replace any existing arbitration agreements,
confidentiality agreements, or restrictive covenant agreements between any Plaintiffs and any
Defendants; such agreements will survive and remain in full force and effect, regardless of
whether or not this Settlement Agreement is approved by the Court.

IN WITNESS WHEREOF, the Parties and their counsel have agreed to and executed this
Settlement Agreement as follows:

NAMED PLAINTIFFS:

_______________________________ Date: __________________
Chad Lyons

_______________________________ Date: __________________
02/10/2025
Christian Taveras

CLASS COUNSEL:

________________________________ Date: __________________
Jack Simpson
Simpson, PLLC

18
48. Binding on Successors and Assigns. This Settlement Agreement shall be binding upon,
and inure to the benefit of, the Plaintiffs and the Released Parties, and their heirs, beneficiaries,
executors, administrators, successors, transferees, assigns, or any corporation or any entity with
which any party may merge, consolidate, or reorganize.

49. Controlling Law. This Settlement Agreement shall be subject to, governed by,
construed, enforced, and administered in accordance with the laws of the State of lowa, without
regard for the principle of conflict of laws.

50. Authorization to Enter_into Settlement Agreement. Counsel for all Parties are
expressly authorized by the Parties whom they represent to enter into this Settlement Agreement
and to take all appropriate action required or permitted to be taken by such Parties pursuant to
this Settlement Agreement to effectuate its terms, and to execute any other documents required
to effectuate the terms of this Settlement Agreement.

51. Counterparts. This Settlement Agreement may be executed in one or more counterparts,
including by facsimile or email. All executed counterparts and each of them shall be deemed to
be one and the same instrument.

IN WITNESS WHEREOF, the Parties and their counsel have agreed to and executed this
Settlement Agreement as follows:

NAMED PLAINTIFFS:

Date:
Chad Lyons

Date:
Christian Taveras

CLASS COUNSEL:

ae Date: ALU as
Jack Simpson
Simpson, PLLC

DEFENDANTS:

Date:
Karen Anapoell
General Counsel, IR Labs DE, LLC

49. Controlling Law. This Settlement Agreement shall be subject to, governed by,
construed, enforced, and administered in accordance with the laws of the State of Iowa, without
regard for the principle of conflict of laws.

50. Authorization to Enter into Settlement Agreement. Counsel for all Parties are
expressly authorized by the Parties whom they represent to enter into this Settlement Agreement
and to take all appropriate action required or permitted to be taken by such Parties pursuant to
this Settlement Agreement to effectuate its terms, and to execute any other documents required
to effectuate the terms of this Settlement Agreement.

51. Counterparts. This Settlement Agreement may be executed in one or more counterparts,
including by facsimile or email. All executed counterparts and each of them shall be deemed to
be one and the same instrument.

IN WITNESS WHEREOF, the Parties and their counsel have agreed to and executed this
Settlement Agreement as follows:

NAMED PLAINTIFFS:

_______________________________ Date: __________________
Chad Lyons

_______________________________ Date: __________________
Christian Taveras

CLASS COUNSEL:

________________________________ Date: __________________
Jack Simpson
Simpson, PLLC

DEFENDANTS:
02 / 14 / 2025
_______________________________ Date: __________________
Rodney Rad
President, IR Labs DE, LLC

18
Docusign Envelope ID: E24B3A03-3786-42BB-80D2-332556CAC014

By:
Name:
IR LABS DE, LLC

Dated:

By:
Name:
SOURCETEK, INC.

2/13/2025
Dated:

4884-5253-6818, v. 2

4
Date:
Michael Llewellyn
President, SourceTek, Inc.

COUNSEL FOR IR LABS DE

Date: [if foes
Wim. R
Jackson Lewis, P.C.

COUNSEL FOR SOURCETEK, INC.:

Date: 4/13/20 aS
Angel West ,
Maynard Nexsen PC

19
EXHIBIT A

Employee ID Numbers of Persons in the IR Labs FLSA Settlement Group

1. 16
2. 17
3. 28
4. 29
5. 35
6. 37
7. 47
8. 50
9. 52
10. 53
11. 56
12. 57
13. 59
14. 60
15. 73
16. 75
17. 77
18. 78
19. 79
20. 81
21. 83
22. 85
23. 88
24. 90
25. 92
26. 98
27. 100
28. 106
29. 108
30. 109
31. 110
32. 114
33. 118
34. 119
35. 120

20
36. 121
37. 122
38. 125
39. 126
40. 129
41. 130
42. 135
43. 136
44. 137
45. 138
46. 140
47. 143
48. 149
49. 152
50. 153
51. 156
52. 158
53. 164
54. 174
55. 178
56. 179
57. 180
58. 181
59. 182
60. 183
61. 185
62. 194
63. 204
64. 246
65. 269
66. 275
67. 278
68. 280
69. 281
70. 283
71. 285
72. 287
73. 289
74. 294
75. 317
76. 318
77. 337
78. 342
79. 361
80. 377
81. 378

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EXHIBIT B

Persons in the IR Labs WARN Settlement Group

1. Adam Doty
2. Adam Sparks
3. Amber Thomas
4. Anthony Heflin
5. April Hawley
6. Austin Becthold
7. Braedi Kinman
8. Brittany J. Bougher-Xam
9. Chad Lyons
10. Dakotah Menaugh
11. Dane Hays
12. Daniel Modell
13. David Lake
14. Dylan Long
15. Erica Brodie
16. Goerden Salazar
17. Charles Somerville
18. Janae Egenberger
19. John Paul Dauber
20. Josh Loeffler
21. Kevin Hatch
22. Marvin Azzopardi
23. Melanie Anderson
24. Oscar Froehlich
25. Stephanie Tessman
26. Taylor Thompson
27. Travis Hummel
28. Tyler Tweeten
29. William Gatchel
30. Zach Meseck

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EXHIBIT C

Persons in the SourceTek Settlement Group

1. Amanda Fox
2. Amber Cloud
3. Ashton Northcutt
4. Charles Marvel
5. Christian Taveras
6. Courtland Fernandez
7. Crystal Stevenson
8. Diego Ferrer
9. Dina Forsythe
10. Esan Shatah
11. Jacqueline Nehall
12. Jennifer Kerrigan
13. Jessica Giddens
14. Joel Lopez
15. Jonathan Carlson
16. Jordan Hoffman
17. Kayli Jenkins
18. Kevin Chambers
19. Laurie Fleming
20. Marqueay Cotto
21. Melissa Painter
22. Melody Lopez
23. Michele Hernandez
24. Radu Christan Dudau
25. Regina Nieves
26. Robin Williams
27. Sabina Gilman
28. Thomas Thomsen
29. Tracy Lewis

EXHIBIT D

EXHIBIT E

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