SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND MOUNTAIN STATES HEALTH ALLIANCE UNDER THE ADA

H. Compensatory Relief for Complainants and Release

93. The Cantrells and MSHA have reached their own agreement regarding the payment of compensatory damages, and they have agreed to keep that amount confidential as part of the consideration for their separate settlement agreement to resolve the Cantrells’ civil action.

94. MSHA’s counsel and the Cantrells’ counsel will be responsible for preparing a settlement agreement and release as between MSHA and the Cantrells for the payment and terms of the compensatory relief mentioned in Paragraph 53.