STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • June 6th, 2022
Contract Type FiledJune 6th, 2022This Stipulation and Agreement of Settlement (together with all Exhibits hereto, the “Settlement Agreement”), dated as of November 16, 2021, which is entered into by and among (i) Plaintiffs Ivan Nibur, Deborah Rath, Jase Luna, Reed Romine, Matthew Willenbucher, and the Duane & Virginia Lanier Trust (the “Plaintiffs”), on behalf of themselves and on behalf of the Settlement Class (as defined herein); and (ii) Settling Defendants Tom L. Ward, Matthew K. Grubb, and James D. Bennett (the “Settling Defendants,” and with the Plaintiffs, the “Settling Parties”), by and through their undersigned attorneys, states all of the terms of the settlement and resolution of this matter by the Settling Parties (as defined herein) and is intended by the Settling Parties to fully and finally release, resolve, remise, and discharge the Released Claims (as defined herein)