STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • April 23rd, 2021 • Arkansas
Contract Type FiledApril 23rd, 2021 JurisdictionThis Stipulation and Agreement of Settlement (“Agreement” or “Settlement”) is entered into between Plaintiff ARcare, Inc. (“Plaintiff” or “ARcare”), on behalf of itself and a class of similarly-situated persons (identified herein as the “Settlement Class”), on the one hand, and QIAGEN North American Holdings Inc. and QIAGEN LLC (formerly QIAGEN Inc.) (together, “Defendants”), on the other. The parties to this Agreement are collectively referred to as the “Parties.” This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims (as the term is defined below), upon and subject to the terms and conditions hereof, and subject to the approval of the Court. This Agreement is entered into as of the date it is signed by the last of the Parties to sign it.