LONG-FORM SETTLEMENT AGREEMENT BETWEEN PLAINTIFFS AND TYSONSettlement Agreement • August 25th, 2021 • New York
Contract Type FiledAugust 25th, 2021 JurisdictionTHIS SETTLEMENT AGREEMENT (“Settlement Agreement”) is made and entered into as of the 30th day of June, 2021 (“Execution Date”), by and between the Plaintiffs (“Plaintiffs”),1 through Interim Co-Lead Counsel for the proposed Settlement Class (defined below), and Tyson Foods, Inc., Tyson Chicken, Inc., Tyson Breeders, Inc., Tyson Poultry, Inc., and all of their predecessors; successors; assigns; Affiliates (including without limitation any affiliates who are alleged co-conspirators); and any and all past, present, and future parents, owners, subsidiaries, divisions, and/or departments (collectively referred to as “Tyson”), in the above-captioned action, including any actions currently or subsequently centralized into this action for coordinated pre-trial proceedings (the “Action”).2 Plaintiffs, on behalf of the proposed Settlement Class, and Tyson are referred to herein collectively as the “Parties” or individually as a “Party.”