SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • July 14th, 2010
Contract Type FiledJuly 14th, 2010Subject to approval by the United States District Court for the Southern District of New York (the “Court”), this Settlement Agreement and Release (“Settlement Agreement,” “Settlement” or “Agreement”) sets forth the full and final terms by which the Class Representatives Amy Velez, Penni Zelinkoff, Minel Hider Tobertga, Michelle Williams, Jennifer Waxman-Recht, Karen Liggins, Lori Horton, Holly Waters, Wendy Pinson, Roberta Vonlintel, Catherine White, Kelly Corbett, Jamie Holland, Joan Durkin, Simona Lopes, Maryanne Jacoby and Marta Deyne (collectively “Class Representatives” or “Named Plaintiffs”), on behalf of a settlement class of themselves and current and former female sales force employees of Novartis Pharmaceuticals Corporation (“Novartis,” “Defendant,” or “Company”) (collectively, the “Settlement Class”), represented by their attorneys, Sanford Wittels & Heisler, LLP and the Law Offices of Grant E. Morris, and Defendant Novartis, represented by its attorneys Cravath, Swaine & M