SETTLEMENT AGREEMENTSettlement Agreement • March 19th, 2014
Contract Type FiledMarch 19th, 2014This Settlement Agreement, dated March 19, 2014 (the “Stipulation” or the “Settlement Agreement”), submitted pursuant to Rule 23 of the Federal Rules of Civil Procedure and Rule 408 of the Federal Rules of Evidence, embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Lead Plaintiffs Jeff Schram and Linda Schram (“Lead Plaintiffs”), on behalf of themselves and each of the members of the Class, as defined in ¶¶1.3-1.4, infra, on the one hand, and (ii) Defendant CNinsure Inc. (“Defendant” or “CNinsure” or the “Company”), on the other hand, by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the Southern District of New York (the “Action”).1 This Stipulation is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims, upon and subject to the terms and conditions hereof and subject to the approval of the Co