Prior to the 2015 Transaction, in 2013, Dr. Kali Pradip Chaudhuri acquired 100% of the shares of Integrated Healthcare Holdings, Inc. Based on a purchase price of $0.203 per share and 255,307,262 shares outstanding, the Complaint alleges that indicates an implied valuation of $51,827,374. After the purchase, Integrated Healthcare Holdings, Inc. was renamed KPC Healthcare Holdings, Inc. On August 28, 2015, the ESOP purchased 100% of the stock of the Company for $217,107,262.

The Complaint alleges that Kali Pradip Chaudhuri engaged in prohibited transactions with respect to the 2015 Transaction, and that the KPC ESOP purchased KPC stock for more than 438% increase over the price that Kali Pradip Chaudhuri paid to acquire the Company less than two years before (and an even greater increase over prices at which the Company had traded publicly prior to Dr. Chaudhuri’s acquisition). The Complaint alleges that Alerus Financial, N.A., the trustee of the ESOP, breached its fiduciary duties in failing to properly investigate the fair market value of KPC stock and in failing to remedy the ESOP’s overpayment of Company stock in the 2015 Transaction. The Complaint also alleges that the Board of Directors of KPC (who also served on the committee that administers the ESOP) breached their fiduciary duties.

This lawsuit is certified on behalf of the following class:

All participants in the KPC ESOP from August 28, 2015 or any time thereafter (unless they terminated employment without vesting in the ESOP) and those participants’ beneficiaries.

Excluded from the Class are (a) Defendants, (b) any fiduciary of the Plan; (c) the officers and directors of KPC or of any entity in which one of the individual Defendants has a controlling interest; (d) the immediate family members of any of the foregoing excluded persons, and (e) the legal representatives, successors, and assigns of any such excluded persons.

The Complaint was filed on June 1, 2020. Defendants filed Motions to Dismiss the Complaint on September 3, 2020, which were denied by the Court on January 15, 2021.

Plaintiff filed a motion for class certification and a motion to amend the complaint. The court held a hearing on those motions on August 6, 2021 and granted both the same day.

Plaintiff filed an Amended Complaint on August 13, 2021. Defendants filed Motions to Dismiss the Amended Complaint on September 3, 2021, which the Court denied on November 1, 2021.

Plaintiff filed a separate lawsuit against SPCP Group, LLC on August 27, 2021 which the Court consolidated with original case on January 21, 2022. The Court certified the claim against SPCP on behalf of the Class on April 5, 2022. On August 15, 2022, the Court granted SPCP’s motion for summary judgment.

Plaintiff and the KPC Defendants reached a settlement in principle on behalf of the Class on May 2, 2022. Plaintiff and Defendant Alerus Financial reached a settlement in principal on behalf of the Class on September 10, 2022. Under the two Settlements, KPC Defendants and Alerus agreed to pay a combined $9 million to resolve the claims. After subtracting court-approved attorneys’ fees, expenses and class representative service awards, the remaining amount of the $9 million total settlement will be distributed to participant Class members (and beneficiaries who would be entitled to payment under the terms of the Plan).

After holding a final fairness hearing on March 10, 2023, the Court granting the Motion for Final Approval and entered Final Judgment.

Plaintiff and the remaining Defendant SPCP Group, reached an agreement on June 5, 2023 whereby SPCP agreed to pay $100,000, which will be paid to class members through the ESOP or 401(k) Plan after payment of any settlement administration costs.

Plaintiff filed the Motion for Preliminary Approval of the Settlement with SPCP Group on July 10, 2023, which was granted by the Court on July 10, 2023. Notice of the SPCP Group Settlement will be provided to the Class by July 21, 2023. Class Members will have until September 5, 2023 to file any objections to the settlement or any Motion for Expenses.

The final fairness hearing on the SPCP Group Settlement will be held on October 20, 2023 at 8:30 a.m. PT at the U.S. Courthouse, Courtroom 6C, 350 West 1st Street, Los Angeles, California 90012.

Once the settlement monies are transferred to the Plan, settlement monies will be distributed to class members (if they are eligible for an immediate distribution) or

transferred to their 401k plan account (if they are not eligible for an immediate distribution) within 30 days. At this time, Class Counsel expects the transfer of the settlement monies to the Plan either later in 2023 or the first part of 2024.

Final Judgment - December 13, 2023

Order Granting Final Approval of SPCP Settlement - October 24, 2023

Order Granting Motion for Preliminary Approval regarding SPCP Group – July 10, 2023

Class Notice regarding SPCP Group

Plan of Allocation regarding SPCP Group

Settlement Agreement with SPCP Group

Motion for Preliminary Approval regarding SPCP Group – June 5, 2023

Final Judgment – March 11, 2023

Order on Final Approval – March 11, 2023

Motion for Final Approval – February 24, 2023

Motion for Attorneys’ Fees – December 30, 2022

Motion for Service Award – December 30, 2022

Order Granting Motion for Preliminary Approval regarding Alerus – November 18, 2022

Class Notice regarding Alerus Settlement

Plan of Allocation regarding Alerus Settlement

Settlement Agreement with Alerus

Motion for Preliminary Approval regarding Alerus Financial – October 7, 2022

Order Granting Motion for Preliminary Approval regarding KPC Defendants – September 29, 2022

Supplemental Brief on Motion for Preliminary Approval regarding KPC Defendants - September 9, 2022

Class Notice regarding KPC Settlement

Plan of Allocation regarding KPC Settlement

Settlement Agreement with KPC Defendants

Motion for Preliminary Approval regarding KPC Defendants – July 25, 2022

Order Granting SPCP’s Motion for Summary Judgment – August 15, 2022

Order Granting Motion for Class Certification regarding SPCP Group – April 5, 2022

Motion for Class Certification regarding SPCP Group – February 16, 2022

Amended Complaint against SPCP Group – November 22, 2021

Complaint against SPCP Group – August 27, 2021

Order Denying Defendants’ Motion to Dismiss Amended Complaint – November 1, 2021

Amended Complaint – August 13, 2021

Motion for Class Certification – May 19, 2021

Order Denying Defendants’ Motion to Dismiss – January 15, 2021

Class Action Complaint – June 1, 2020