Common Contracts
1 similar Stipulation and Agreement of Settlement contracts
STIPULATION AND AGREEMENT OF SETTLEMENTStipulation and Agreement of Settlement • September 17th, 2019
This Stipulation and Agreement of Settlement, dated as of August 6, 2019 (the “Stipulation”) is entered into between (a) Lead Plaintiffs Robert Spock and Duck Pond Partners, LP, on behalf of themselves and the Settlement Class (defined below), and (b) defendant Rockwell Medical, Inc. (“Rockwell”) and defendants Robert L. Chioini and Thomas E. Klema (collectively, the “Individual Defendants”; and, together with Rockwell, the “Defendants”; and together with Lead Plaintiffs, the “Parties”), 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, relinquish, waive and discharge each and every Released Plaintiffs’ Claim against the Defendants and the other Defendants’ Releasees.
