STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • March 22nd, 2007 • New York
Contract Type FiledMarch 22nd, 2007 JurisdictionThis stipulation and agreement of settlement is made and entered into by and between Lead Plaintiffs Hermes Focus Asset Management Europe Limited, Cattolica Partecipazioni, S.p.A., Capital & Finance Asset Management, Societe Moderne des Terrassements Parisiens and Solotrat (“Lead Plaintiffs”), on their own behalf and on behalf of all other purchasers of securities of Parmalat Finanziaria S.p.A. and its subsidiaries and affiliates (“Parmalat” or the “Company”) between and including January 5, 1999 and December 18, 2003 (the “Class Period”), and Defendant Banca Nazionale del Lavoro S.p.A. (“BNL”), Defendant Credit Suisse Group (“CSG”), Defendant Credit Suisse (“CS”), Defendant Credit Suisse International (“CSI”), and Defendant Credit Suisse Securities (Europe) Limited (“CSS”) (Defendants CSG, CS, CSI and CSS collectively will be referred to as the “Credit Suisse Defendants”) (collectively the “Parties”).