Extract to table

Additionally, within forty-eight (48) hours of entry of the order, Farris shall request the removal or retraction of all statements made during podcast appearances in which he disparaged AHT or disclosed AHT Confidential Information, including but not limited to the January 15, 2025 episode of The Digital Health Download and the March 4, 2025 episode of HealthTech Insider, and shall use his best efforts to secure such removal or retraction

Section 10 of the Separation Agreement sets forth the remedies available to AHT in the event of Farris's breach of any of the restrictive covenants in Sections 6 through 9: (a) Clawback of Cash Severance (§ 10(a)): Upon breach, Farris is obligated to repay all cash severance payments received under Section 3(a), and AHT's obligation to make any remaining severance payments shall immediately terminate; (b) Clawback of Stock Option Value (§ 10(b)): Upon breach, Farris is obligated to disgorge the value of the accelerated stock option vesting received under Section 3(c), and any unexercised accelerated options shall be immediately forfeited; (c) Injunctive Relief Without Bond (§ 10(c)): AHT shall be entitled to seek and obtain temporary, preliminary, and permanent injunctive relief, including specific performance, to enforce the restrictive covenants, without the posting of any bond or other security; (d) Liquidated Damages and Actual Damages (§ 10(d)): In the event of a breach of Sections 6 or 7, Farris shall pay liquidated damages to AHT in the amount of $250,000, plus actual damages to the extent such damages exceed the liquidated amount

Section 14 of the Separation Agreement provides that the Agreement shall be governed by and construed in accordance with the laws of the Commonwealth of Massachusetts, without regard to its conflicts of law principles

Section 16 provides that the prevailing party in any action to enforce the Agreement shall be entitled to recover its reasonable attorneys' fees and costs

The movant must demonstrate a likelihood of success on the merits of the underlying claims

The movant need not show that success is certain, but must present a substantial basis for the claims that would warrant relief