Common Contracts

STIPULATION AND AGREEMENT OF SETTLEMENT

Settlement Agreement • December 5th, 2022

• Contract Type
  Settlement Agreement
• Filed
  December 5th, 2022

This Stipulation and Agreement of Settlement (the “Stipulation” or “Settlement Agreement”) is made and entered into by and between (a) Court-appointed Class Representatives Oklahoma Firefighters Pension and Retirement System (“OFPRS”), Plymouth County Retirement Association (“PCRA”) and Electrical Workers Pension Fund, Local 103, I.B.E.W. (“Local 103”) (collectively, “Class Representatives”), on behalf of themselves and all other members of the Court-certified Class (defined below), on the one hand, and (b) Defendants Conduent Incorporated (“Conduent” or the “Company”), Ashok Vemuri, and Brian Webb-Walsh (the “Individual Defendants”, and together with Conduent the “Defendants” and, together with both Conduent and the Class Representatives, the “Parties”), on the other, by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the District of New Jersey (the “Court”). This Stipulation is intended by the Parties to fully, fin