Common Contracts

STIPULATION AND AGREEMENT OF SETTLEMENT WITH REMAINING DEFENDANTS

Stipulation and Agreement of Settlement • February 4th, 2015

• Contract Type
  Stipulation and Agreement of Settlement
• Filed
  February 4th, 2015

This stipulation and agreement of settlement (the “Stipulation”) is made and entered into by and between Lead Plaintiffs, Arkansas Teacher Retirement System (“ATRS”), State-Boston Retirement System (“State-Boston”), Norfolk County Retirement System (“Norfolk”), and City of Brockton Retirement System (“Brockton”) (collectively, “Lead Plaintiffs”) on behalf of themselves, Plaintiff The Horace F. Moyer and Joan M. Moyer Living Trust, Plaintiff City of Worcester Retirement System, and the proposed Settlement Class (defined below), on the one hand, and the Underwriter Defendants (defined below) and PricewaterhouseCoopers LLP (“PwC”) (collectively, “Defendants”) and the Tolled Defendants (defined below), on the other hand.