My cient took out $137,000 from his 401k plan.  It caused a 10% penalty for early withdrawal.

In 2020 he tested positive for Covid, was laid off from his job for a while, had a car accident which caused $7,000+ medical bills, and had to move to a new appartment.  How much can I say is exempt from the 10% penalty?  Can I exempt the max of $100,000?