Common Contracts
1 similar Stipulation and Agreement of Settlement contracts
STIPULATION AND AGREEMENT OF SETTLEMENTStipulation and Agreement of Settlement • February 7th, 2020 • New York
This Stipulation and Agreement of Settlement, dated as of February 5, 2020 (the “Stipulation”) is entered into between (a) the Alameda County Employees’ Retirement Association (“ACERA”) and the Orange County Employees’ Retirement System (“OCERS” and, together with ACERA, the “Lead Plaintiffs”), on behalf of themselves and the Settlement Class (defined below); and (b) defendants Vale S.A. (“Vale”), and Murilo Pinto de Oliveira Ferreira, Luciano Siani Pires, and Gerd Peter Poppinga (collectively, the “Individual Defendants,” and, together with Vale, 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 all claims asserted in the Action against Defendants.
