Stipulation and Agreement Sample Contracts

RECITAL
Stipulation and Agreement • April 7th, 2005 • White River Capital Inc • Creek
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STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement • March 3rd, 2022 • New York

This Stipulation and Agreement of Settlement (the “Stipulation”) is made and entered into by and between Walleye Trading LLC and Walleye Opportunities Master Fund Ltd. (“Co-Lead Plaintiffs”), on behalf of themselves and all other members of the Settlement Class (defined below), on the one hand, and Mindbody, Inc. (“Mindbody” or the “Company”), Richard L. Stollmeyer, Brett White, and Eric Liaw (collectively, the “Individual Defendants” and, with Mindbody, “Defendants”), on the other, and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”). This Stipulation is intended by Co-Lead Plaintiffs and Defendants (collectively, the “Parties”) to fully, finally, and forever resolve, discharge, and settle the Released Plaintiff’s Claims as against the Released Defendant Parties and the Released Defendants’ Claims as against the Released Plaintiff Parties (each of these capitalized terms is defined below), upon and subject to the terms and conditions her

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
Stipulation and Agreement • February 28th, 2024
STIPULATION AND AGREEMENT OF ) SETTLEMENT
Stipulation and Agreement • November 11th, 2021

This Stipulation and Agreement of Settlement (together with all Exhibits hereto, the “Settlement Agreement”), dated as of November 12, 2021, which is entered into by and among: (i) Plaintiffs and Class Representatives Laborers Pension Trust Fund for Northern Nevada (“Northern Nevada”), Construction Laborers Pension Trust of Greater St. Louis (“Greater St. Louis”), and Angelica Galkin (collectively, “Plaintiffs”), on behalf of themselves and on behalf of the Class Members (as defined herein); and (ii) Settling Defendants Tom L. Ward, James D. Bennett, and Matthew K. Grubb (the “Settling Defendants,” and with the Plaintiffs, the “Settling Parties”), by and through their undersigned attorneys, states all of the terms of the settlement and resolution of this matter by the Settling Parties (as defined herein) and is intended by the Settling Parties to fully and finally release, resolve, remise, and discharge the Released Claims (as defined herein) against the Released Persons (as defined he

STIPULATION AND AGREEMENT OF
Stipulation and Agreement • May 7th, 2020

This Stipulation and Agreement of Settlement dated as of May 8, 2020 (the “Stipulation”), is made and entered into by and among: (i) District No. 9, I.A. of M & A.W. Pension Trust (on behalf of itself and each of the Class Members), by and through its counsel of record in the Litigation (as defined herein); and (ii) Defendants Lexmark International, Inc. (“Lexmark” or the “Company”), and Paul A. Rooke, David Reeder, and Gary Stromquist (the “Individual Defendants,” and collectively, with Lexmark, the “Defendants”), by and through their counsel of record in the Litigation. The Stipulation is intended to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined herein), subject to the approval of the Court and the terms and conditions set forth in this Stipulation.

BEFORE THE PUBLIC SERVICE COMMISSION OF THE STATE OF MISSOURI
Stipulation and Agreement • May 16th, 2013

In the Matter of the Application of KCP&L Greater ) Missouri Operations Company for Authority to ) Extend the Transfer of Functional Control of Certain ) Transmission Assets to the Southwest Power Pool, ) Inc. )

Contract
Stipulation and Agreement • December 15th, 2009 • Retail Ventures Inc • Retail-variety stores • Delaware

This stipulation and agreement (this “Agreement”) memorializes the parties’ agreement (the “RVI/DSW Settlement”) with respect to certain terms relating to a comprehensive settlement including, without limitation, (i) a compromise and settlement of all rights, claims, defenses and counterclaims involving Retail Ventures, Inc. and its officers, directors and subsidiaries other than DSW (as hereinafter defined) (collectively, “RVI”) and (ii) a compromise and settlement of all rights, claims, defenses and counterclaims involving DSW, Inc. and its officers, directors and subsidiaries (collectively, “DSW”).

BEFORE THE PUBLIC SERVICE COMMISSION OF THE STATE OF MISSOURI
Stipulation and Agreement • September 15th, 2020

In the Matter of Spire Missouri Inc.’s Verified Application for an Accounting Authority Order Related to COVID-19 Impacts )))) Case No. GU-2020-0376

STIPULATION AND AGREEMENT OF : SETTLEMENT WITH BANK OF AMERICA
Stipulation and Agreement • August 17th, 2017

This Stipulation and Agreement of Settlement (“Stipulation” or “Agreement”) is made and entered into on August 11 , 2017 (“Execution Date”), between (i) on the one hand, Plaintiffs Sheet Metal Workers Pension Plan of Northern California, KBC Asset Management NV, and Iron Workers Pension Plan of Western Pennsylvania (collectively, “Class Plaintiffs”), for themselves individually and on behalf of all Settlement Class Members as defined herein, and, (ii) on the other hand, Bank of America Corporation, Bank of America, N.A., Bank of America Merrill Lynch International Limited, Merrill Lynch International, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (collectively, “Bank of America,” “BofA,” or “Settling Defendant”), by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the Southern District of New York. Class Plaintiffs and Settling Defendant are collectively referred to herein as the “Parties.” This Agreement is

SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Stipulation and Agreement • June 21st, 2010 • Smart Online Inc • Services-prepackaged software • Delaware

This Settlement Agreement and Mutual Release (“Settlement Agreement”), dated the 18st day of June, 2010, is entered into by and between DENNIS MICHAEL NOURI, REZA ERIC NOURI, HENRY NOURI, and RONNA LOPRETE NOURI (collectively, the “Nouris”) on the one hand, and SMART ONLINE, INC. (the “Company”), on the other hand (the Nouris, together with the Company, the “Parties”).

SETTLEMENT AGREEMENT
Stipulation and Agreement • September 6th, 2016 • New York

Agreement”) is made and entered into on September 6, 2016. This Settlement Agreement is entered into on behalf of Representative Plaintiffs Norman Bailey, Robert Ceru, Christopher DePaoli, John Hayes, Laurence Hughes, KPFF Investment, Inc. f/k/a KP Investment, Inc., Kevin Maher, Eric Nalven, J. Scott Nicholson, and Don Tran (collectively, the “Representative Plaintiffs”) for themselves and on behalf of the Settlement Class (as defined in Section 1(E) herein), by and through Representative Plaintiffs’ Interim Co-Lead Counsel (as defined in Section 1(W) herein), and on behalf of Defendants Deutsche Bank AG; Deutsche Bank Americas Holding Corporation, DB U.S. Financial Markets Holding Corporation, Deutsche Bank Securities, Inc.; Deutsche Bank Trust Corporation, Deutsche Bank Trust Company Americas; Deutsche Bank AG New York Branch (collectively, “Deutsche Bank”), by and through their undersigned counsel of record in this Action.

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement • November 1st, 2012

This Settlement Agreement is entered into this 1st day of November, 2012 by and among the named plaintiffs: (1) Custom Underground, Inc.; (2) John Barrett; (3) Scott and Heather Gray; (4) Frank Brown Towing, Inc.; (5) Cecil and Tressie Fulton; (6) Karl Strong; (7) Dinonno Enterprises, Inc., d/b/a Cutting Edge Concrete Cutting; (8) Charles Clark; (9) Georgean Vogt;

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement • July 12th, 2016 • Lumber Liquidators Holdings, Inc. • Retail-lumber & other building materials dealers

This Stipulation and Agreement of Settlement, dated as of June 15, 2016 (the “Stipulation”), is entered into between (a) Gregg Kiken, Keith Foster, David Lorenzo and Charles Hickman (collectively “Lead Plaintiffs”), on behalf of themselves and the Settlement Class (defined below); and (b) defendant Lumber Liquidators Holdings, Inc. (“Lumber Liquidators”), and defendants Thomas D. Sullivan, Robert M. Lynch, Daniel E. Terrell and William K. Schlegel (collectively, the “Individual Defendants,” and, together with Lumber Liquidators, the “Defendants”) by and through their respective undersigned counsel, and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”).1 Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever compromise, settle, release, resolve, and dismiss with prejudice the Action and all claims asserted therein against Defendants.

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION
Stipulation and Agreement • September 22nd, 2005 • Firstplus Financial Group Inc • Personal credit institutions
STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement • December 18th, 2006 • New York

Exhibit F -- Final Judgment and Order of Dismissal Exhibit G -- Class and Settlement Notice Plan Exhibit H -- Plan of Administration and Distribution Exhibit I -- Exemplar Documents

Stipulation for settlement form california
Stipulation and Agreement • July 1st, 2020

Exhibit 99.2 STIPULATION AND AGREEMENT OF SETTLEMENT This Stipulation and Agreement of Settlement (“Stipulation”) dated May 4, 2011, is made and entered into by and among the following Parties: (i) City of Pontiac Policeman’s and Fireman’s Retirement System and Robert B. Minich (“Plaintiffs”), individually and derivatively on behalf of Fossil, Inc. (“Fossil” or the “Company”); (ii) Tom Kartsotis, Kosta N. Kartsotis, Michael W. Barnes, Jal S. Shroff, Alan J. Gold, Kenneth W. Anderson, Donald J. Stone, Michael Steinberg, Caden Wang, Richard H. Gundy, Mark D. Quick, Randy S. Kercho, Michael L. Kovar, Thomas R. Tunnell, Randy S. Hyne, Stephen Bock, and Junichi Hattori (the “Individual Defendants”); and (iii) Fossil, by and through its counsel of record in the Action. This Stipulation is intended by the Parties to fully, finally, and forever compromise, resolve, discharge, and settle the Released Claims and dismiss the Action with prejudice, upon the terms and subject to the conditions set

STIPULATION AND AGREEMENT OF CLASS ACTION SETTLEMENT
Stipulation and Agreement • May 23rd, 2023 • Texas

This Stipulation and Agreement of Settlement, as of the date of execution below (the “Settlement Agreement,” “Settlement,” “Agreement,” or “Stipulation”), is made and entered into by and among the following settling parties (“Parties”): (i) Connie Yuan (“Plaintiff” or “Settlement Class Representative”), individually and on behalf of the Settlement Class (defined below); and

NON-UNANIMOUS STIPULATION AND AGREEMENT
Stipulation and Agreement • February 28th, 2020

COMES NOW Union Electric Company d/b/a Ameren Missouri (“Ameren Missouri” or “the Company”), the Staff of the Missouri Public Service Commission (“Staff”), the Office of the Public Counsel ("OPC"), Missouri Department of Natural Resources - Division of Energy ("DE"), Missouri Industrial Energy Consumers ("MIEC"), Midwest Energy Consumers Group ("MECG"), Consumers Council of Missouri ("CCM"), Natural Resources Defense Council, and the Sierra Club (collectively “Signatories”), and present to the Missouri Public Service Commission (“Commission”) for approval this Stipulation and Agreement (“Stipulation”) commemorating an agreement between the Signatories resolving, except as reserved herein, the issues in this case related to Ameren Missouri's revenue requirement and rate design. Renew Missouri Advocates has authorized the Signatories to indicate that it does not object to this Stipulation. In support of this Stipulation, the Signatories respectfully state as follows:

FILED
Stipulation and Agreement • August 29th, 2013
STIPULATION AND AGREEMENT
Stipulation and Agreement • October 3rd, 2019

COMES NOW KCP&L Greater Missouri Operations Company (“GMO”), by and through, and for this Stipulation and Agreement (“Stipulation”)1, respectfully states as follows to the Missouri Public Service Commission (“Commission”):

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA
Stipulation and Agreement • April 18th, 2016
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STIPULATION AND AGREEMENT OF COMPROMISE AND SETTLEMENT
Stipulation and Agreement • October 5th, 2011

This Stipulation and Agreement of Compromise and Settlement (the “Stipulation”), dated October 5, 2011, which is entered into by and among (i) Plaintiff NECA-IBEW Pension Fund (The Decatur Plan) (“Lead Plaintiff”), on its own behalf and on behalf of the Settlement Class (as defined herein); (ii) Kohlberg Kravis Roberts & Co. L.P. (“KKR”), Vestar Capital Partners (“Vestar”), Centerview Capital, L.P. (named in the Action (as defined below) as Centerview Partners, “Centerview”), Blue Acquisition Group, Inc., and Blue Merger Sub Inc. (collectively, the “Sponsors”); (iii) Barclays Capital Inc. (“Barclays”); (iv) Richard G. Wolford, Samuel H. Armacost, Timothy G. Bruer, Mary R. Henderson, Victor L. Lund, Terence D. Martin, Sharon L. McCollam, Joe L. Morgan, and David R. Williams (the “Director Defendants”); and (v) Del Monte Corporation, as successor-in-interest to Del Monte Foods Company (together, the “Del Monte Companies” and collectively, with the Sponsors, Barclays, and the Director Def

BEFORE THE PUBLIC SERVICE COMMISSION OF THE STATE OF MISSOURI
Stipulation and Agreement • August 30th, 2022

In the Matter of Evergy Metro, Inc. d/b/a Evergy Missouri Metro’s Request for Authority to Implement A General Rate Increase for Electric Service )) Case No. ER-2022-0129)) In the Matter of Evergy Missouri West, Inc. d/b/a ) Evergy Missouri West’s Request for Authority to ) Case No. ER-2022-0130 Implement A General Rate Increase for Electric ) Service )

BEFORE THE DEPARTMENT OF REAL ESTATE
Stipulation and Agreement • December 6th, 2011
STIPULATION AND AGREEMENT
Stipulation and Agreement • January 29th, 2020

COMES NOW Union Electric Company d/b/a Ameren Missouri ("Company" or "Ameren Missouri"), the Staff of the Missouri Public Service Commission (“Staff”), the Office of the Public Counsel (“OPC”), and the Missouri Industrial Energy Consumers (“MIEC”) (collectively referred to hereinafter as the “Signatories”),1 and hereby submit this Stipulation and Agreement (“Stipulation”), as follows:

STATE OF CALIFORNIA
Stipulation and Agreement • April 17th, 2012

w and waivers and solely for the purpose of settlement of the pending Accusation without a hearing, it is stipulated and agreed that the following determination of issues shall be made:

BEFORE THE PUBLIC SERVICE COMMISSION OF THE STATE OF MISSOURI
Stipulation and Agreement • January 30th, 2019

Approval and a Certificate of Public Convenience and ) File No. EA-2019-0021 Necessity Authorizing it to Construct a Wind Generation )

MAR 3 0 2007
Stipulation and Agreement • March 28th, 2012
IN THE United States District Court FOR THE DISTRICT OF DELAWARE
Stipulation and Agreement • March 8th, 2021 • Impinj Inc • Electronic components, nec

This Stipulation and Agreement of Settlement dated July 10, 2020 (the “Stipulation”), is made and entered into by and among the following Parties (as defined below), each by and through their respective counsel: (i) plaintiffs to the above-captioned consolidated shareholder derivative action, Mohammed Fotouhi (“Fotouhi”), Fred Weiss (“Weiss”), David Plaza de la Fuente (“de la Fuente”), and Jesus Ladron Sanchez, (“Sanchez” and collectively, “Plaintiffs”), derivatively on behalf of Impinj, Inc. (“Impinj” or the “Company”); (ii) nominal defendant Impinj; and (iii) current and former officers and/or member of Impinj’s Board of Directors (the “Board”), defendants Chris Diorio, Eric Brodersen, Evan Fein, Gregory Sessler, Tom A. Alberg, Clinton Bybee, Peter Van Oppen, and Theresa Wise (the “Individual Defendants” and with Impinj, the “Defendants”). This Stipulation, subject to the approval of the United States District Court for the District of Delaware (the “Court”), is intended by the Parti

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA
Stipulation and Agreement • August 22nd, 2019
BEFORE THE PUBLIC SERVICE COMMISSION OF THE STATE OF MISSOURI
Stipulation and Agreement • March 11th, 2015

The Staff of the Missouri Public Service Commission, Complainant, vs. Laclede Gas Company, doing business as Missouri Gas Energy, and Southern Union Company, formerly doing business as Missouri Gas Energy Respondents. )))))))))))))))) Case No. GC-2014-0216

DEPARTMENT OF REAL ESTATE
Stipulation and Agreement • September 23rd, 2011
STIPULATION AND AGREEMENT
Stipulation and Agreement • October 25th, 2018

COME NOW Union Electric Company d/b/a Ameren Missouri ("Ameren Missouri" or the "Company"), Staff of the Missouri Public Service Commission ("Staff"), the Office of the Public Counsel ("OPC"), Missouri Division of Energy ("DE"), Consumers Council of Missouri, Renew Missouri Advocates d/b/a Renew Missouri, National Housing Trust, and Tower Grove Neighborhood Community Development Corporation, (collectively referred to as "Signatories"), and submit this Stipulation and Agreement ("Stipulation") for approval by the Missouri Public Service Commission ("Commission"). All parties to this proceeding have either signed this Stipulation or have indicated they will not oppose this Stipulation.1

APR 3 0 2004
Stipulation and Agreement • November 22nd, 2011

w Commissioner of the State of California, makes this Accusation against Respondents in his official capacity and not otherwise.

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