CLASS ACTION SETTLEMENT AND RELEASE AGREEMENTSettlement and Release Agreement • March 15th, 2011
Contract Type FiledMarch 15th, 2011The Plaintiffs, who are acting as the Class Representatives on behalf of themselves and all other Settlement Class Members of the Settlement Classes set forth herein, and IPEX Inc. and IPEX USA LLC, on behalf of the IPEX Defendants, stipulate and agree, pursuant to the terms and conditions set forth in this Agreement, to settle, dismiss, and compromise fully and finally the U.S. Kitec MDL Class Action and the Canadian Actions.