CLASS ACTION SETTLEMENT AGREEMENTClass Action Settlement Agreement • October 2nd, 2024 • Texas
Contract Type FiledOctober 2nd, 2024 JurisdictionThis Class Action Settlement Agreement (“Settlement Agreement”), dated October 2, 2024, is made and entered into by and among Plaintiffs Leslie Urlaub, Mark Pellegrini, and Mark Ferry (“Plaintiffs” or “Class Representatives”), on behalf of themselves, the Plans (for purposes of their claims under 29 U.S.C. § 1132(a)(2)), and each of the Class Members (as defined below), on the one hand, and Defendants CITGO Petroleum Corporation, the Benefit Plans Committee, and the Plans (as defined below), on the other hand (collectively, “Defendants”) (Plaintiffs (including the Class Members) and Defendants are, collectively, “Parties,” or any of them, a “Party”), subject to the approval of the Court, pursuant to Rule 23(e) of the Federal Rules of Civil Procedure.