STIPULATION AND AGREEMENT OF SETTLEMENTStipulation and Agreement of Settlement • April 13th, 2020 • Indiana
Contract Type FiledApril 13th, 2020 JurisdictionThis Stipulation and Agreement of Settlement, dated as of April 14, 2020 (the “Stipulation”) is entered into between (a) Lead Plaintiffs Rajesh M. Shah and Matt Brierley (“Lead Plaintiffs”), and additional plaintiffs UFCW Local 1500 and Steven Castillo (together with Lead Plaintiffs, “Plaintiffs”), on behalf of themselves and the Settlement Class (defined below); and (b) defendant Zimmer Biomet Holdings, Inc. (“ZBH” or the “Company”), defendants David C. Dvorak, Daniel P. Florin, Robert J. Marshall Jr., Tony W. Collins (collectively the “Officer Defendants”), and defendants Christopher B. Begley, Betsy J. Bernard, Paul M. Bisaro, Gail K. Boudreaux, Michael J. Farrell, Larry Glasscock, Robert A. Hagemann, Arthur J. Higgins, Michael W. Michelson, Cecil B. Pickett, Ph.D., Jeffrey K. Rhodes (together with the Officer Defendants, the “Individual Defendants,” and, together with ZBH and the Officer Defendants, the “Defendants”), and embodies the terms and conditions of the settlement of the a