SETTLEMENT AGREEMENTSettlement Agreement • December 28th, 2022
Contract Type FiledDecember 28th, 2022This Settlement Agreement is made and entered into on December 23, 2022, by and between Novartis Pharmaceuticals Corporation and Novartis AG (collectively “Novartis” or “Defendants”), by and through their counsel Cravath, Swaine & Moore LLP; and Drogueria Betances, LLC (“Betances”), Rochester Drug Co-Operative, Inc. (“RDC”), FWK Holdings, LLC (“FWK”) and KPH Healthcare Services, Inc., a/k/a Kinney Drugs, Inc. (“KPH”) (collectively, “Named Plaintiffs”), individually and on behalf of the Direct Purchaser Class (as defined in Paragraph 1 below, the “Direct Purchaser Class” or “Class”), by and through Garwin Gerstein & Fisher LLP, in its capacity as interim lead counsel for the Direct Purchaser Class (“Plaintiffs’ Counsel”) in the above-captioned litigation. This Settlement Agreement is intended to, and upon occurrence of the Effective Date will, fully, finally, and forever resolve, compromise, discharge, and settle the claims of the Direct Purchaser Class against Novartis in the above-cap