STIPULATION OF SETTLEMENTSettlement Agreement • September 23rd, 2019
Contract Type FiledSeptember 23rd, 2019This stipulated Settlement Agreement dated September 23, 2019 (the “Stipulation” or the “Settlement Agreement”) embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Plumbers and Pipefitters National Pension Fund (“Plumbers and Pipefitters”), United Association Local Union Officers & Employees’ Pension Fund (the “UA Fund”), and the Department of the Treasury of the State of New Jersey and its Division of Investment (“New Jersey”) (collectively, Plumbers and Pipefitters, the UA Fund, and New Jersey are hereinafter referred to as “Lead Plaintiffs” or “Plaintiffs”), on behalf of themselves and each of the Class Members, and (ii) Defendants Trinity Industries, Inc. (“Trinity” or the “Company”), Timothy R. Wallace, James E. Perry, and Gregory B. Mitchell (collectively, “Defendants”), by and through their counsel of record in the above-captioned consolidated litigation (the “Action”) pending in the United States District Court for the
SETTLEMENT AGREEMENTSettlement Agreement • June 14th, 2017
Contract Type FiledJune 14th, 2017This Settlement Agreement dated June 14, 2017, 2017 (the “Stipulation” or the “Settlement Agreement”) embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Lead Plaintiff the National Shopmen Pension Fund (“NSPF” or “Lead Plaintiff”), on behalf of itself and each of the members of the Class, as defined in ¶¶1.3-1.4, infra, on the one hand, and (ii) Defendants J.C. Penney Company, Inc. (“JCPenney”), Myron E. Ullman, III, and Kenneth H. Hannah (collectively, “Defendants” ), on the other hand, by and through their counsel of record in the above-captioned consolidated litigation pending in the United States District Court for the Eastern District of Texas (the “Action”). The Stipulation is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims, upon and subject to the terms and conditions hereof and subject to the approval of the Court. Throughout this Stipulation, all capi