SETTLEMENT AGREEMENTSettlement Agreement • June 18th, 2015
Contract Type FiledJune 18th, 2015This Settlement Agreement (“Agreement”) is entered into on June 18, 2015, by and among the following parties acting by and through their respective undersigned counsel: (i) Ira Bodenstein (the “Trustee”), not personally, but as Chapter 7 Trustee for the estate of Peregrine Financial Group, Inc. (“PFG”) in the proceeding captioned In re Peregrine Financial Group, Inc., Case No. 12-B-27488 (the “Bankruptcy Case”), pending in the United States Bankruptcy Court for the Northern District of Illinois (the “Bankruptcy Court”), (ii) U.S. Bank National Association (“U.S. Bank”) and (iii) Brian Pannkuk, Jordan Robinson, Joe Martano, Marcus Ibrahim, William Robert Evans, III, Gurvaneet Randhawa, and Patricia Benvenuto, as well as any additional class representative plaintiffs as are appointed or may be appointed in the future by the District Court in the Customer Class Action (as defined herein) (collectively, the “Customer Representative Plaintiffs”) by and through their respective counsel in th