Common Contracts

1 similar Stipulation and Agreement of Compromise and Settlement contracts

STIPULATION AND AGREEMENT OF COMPROMISE AND SETTLEMENT
Stipulation and Agreement of Compromise and Settlement • December 6th, 2017

This Stipulation and Agreement of Compromise and Settlement (the “Stipulation”), dated December 6, 2017, is entered into by and among the following Parties in the Action: (i) Suhas Patel (“Plaintiff”), on behalf of himself and all other members of the Class, and (ii) Defendants Galena Biopharma, Inc. (“Galena” or the “Company”), William L. Ashton, Rudolph Nisi, Richard Chin, Irving Einhorn, Stephen Galliker, Sanford Hillsberg, Mary Ann Gray, Mark W. Schwartz and Stephen F. Ghiglieri (collectively, the “Defendants”). This Stipulation sets forth all of the terms of the settlement and resolution of this matter and is intended by Plaintiff and Defendants to fully and finally release, resolve, remise, compromise, settle and discharge the Released Plaintiff’s Claims against the Released Defendant Persons and the Released Defendants’ Claims against the Releasing Plaintiff Persons, subject to the approval of the Court of Chancery of the State of Delaware (the “Court”), without any admission or

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