STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • March 31st, 2020
Contract Type FiledMarch 31st, 2020This Stipulation and Agreement of Settlement (the “Stipulation”) is entered into by and between Court-appointed Lead Plaintiff Raymond Balestra (“Lead Plaintiff”) on behalf of himself and the Class (as defined below), and Defendants ATBCOIN LLC (“ATB”), Edward Ng (“Edward”), and Herbert W. Hoover (“Herbert”) (collectively, “Defendants”) by and through their respective counsel.1 The Stipulation is intended by Lead Plaintiff and the Defendants (collectively, the “Parties”) to fully, finally, and forever resolve, discharge, release and settle the Settled Claims, as defined below, upon and subject to the terms and conditions hereof.