SETTLEMENT AGREEMENT BETWEEN BONDHOLDER PLAINTIFFS ANDSettlement Agreement • September 20th, 2021
Contract Type FiledSeptember 20th, 2021This Settlement Agreement is made and entered into on September 20, 2021 (the “Execu- tion Date”), between Plaintiffs Ellen Gelboim and Linda Zacher (collectively, the “Bondholder Plaintiffs”), individually and on behalf of the Bondholder Class in the Bondholder Action, and defendant MUFG Bank, Ltd. (f/k/a The Bank of Tokyo-Mitsubishi UFJ, Ltd.) (“MUFG”), by and through Bondholder Plaintiffs’ Counsel and MUFG’s Counsel, respectively. This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims, upon and subject to the terms and conditions hereof.