LONG-FORM SETTLEMENT AGREEMENT BETWEEN DIRECT PURCHASER PLAINTIFFS AND TYSON FOODSSettlement Agreement • May 14th, 2021 • Illinois
Contract Type FiledMay 14th, 2021 JurisdictionTHIS SETTLEMENT AGREEMENT, (“Settlement Agreement”) is made and entered into as of the 14th day of May, 2021 (“Execution Date”) by and between the Direct Purchaser Plaintiffs (“DPPs”),1 through Interim Co-Lead Counsel (as hereinafter defined) for the proposed Settlement Class (as hereinafter defined), and Tyson Foods, Inc., Tyson Fresh Meats, Inc., Tyson Prepared Foods, Inc. and the Hillshire Brands Company and all of their predecessors, successors, assigns, and Affiliates (as hereinafter defined) (including without limitation any affiliates who are alleged co-conspirators); and any and all past, present, and future parents, owners, subsidiaries, divisions, departments (collectively referred to as “Settling Defendant” or “Tyson”) in the above-captioned action (the “Action”). DPPs, on behalf of the Settlement Class, and Tyson are referred to herein collectively as the “Parties” or individually as a “Party.”