Common Contracts

STIPULATION AND AGREEMENT OF COMPROMISE AND SETTLEMENT

August 31st, 2011

• Filed
  August 31st, 2011

This Stipulation and Agreement of Compromise and Settlement (the “Stipulation”), dated August 30, 2011, which is entered into by and among (i) New Orleans Employees’ Retirement System, Local 542 International Union of Operating Engineers Pension Fund of Eastern Pennsylvania and Delaware, City of Orlando Police Pension Fund, Southeastern Pennsylvania Transportation Authority, City of Orlando Firefighters’ Pension Fund and Martin Vogel (collectively, “Lead Plaintiffs”), on their own behalf and on behalf of the Settlement Class (as defined herein); and (ii) J.Crew Group, Inc. (hereafter, “J.Crew” or the “Company”), Millard Drexler (“Drexler”), James Coulter (“Coulter”), David House (“House”), Heather Reisman (“Reisman”), Stuart Sloan (“Sloan”), Mary Ann Casati (“Casati”), Josh Weston (“Weston”), Steven Grand-Jean (“Grand-Jean”), Stephen Squeri (“Squeri”), James Scully (“Scully”), TPG Capital, L.P., TPG Partners, VI, L.P. (together with TPG Capital, L.P., “TPG”), Leonard Green & Partners,