C. The Release Provisions Bar Claims Not Addressed And/Or Remedied In These Agreements
The release provisions are also overbroad because they bar litigation concerning access issues that the Agreements do not address and/or remedy. Furthermore, it is unclear whether these Agreements even address all of the ADA violations that were at issue in this case. Without reviewing and verifying a detailed expert report about access at each facility, and reviewing every written or unwritten hospital policy, a class member cannot, at this time determine, if the Agreements resolve (or even identify) all accessibility issues that may affect him.
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