UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISIONSettlement Agreement • July 16th, 2018 • Texas
Contract Type FiledJuly 16th, 2018 JurisdictionThis Stipulation and Agreement of Settlement, dated as of July 16, 2018 (the “Stipulation”) is entered into between: (a) Lead Plaintiffs Cynthia A. Parmelee and Kelly Baxley (collectively, “Lead Plaintiffs”), on behalf of themselves and the Settlement Class (defined below); and (b) defendant Santander Consumer USA Holdings, Inc. (“Santander”) and defendants Thomas G. Dundon, Jason Kulas, Ismail Dawood, and Jennifer Davis (collectively, the “Individual Defendants,” and, together with Santander, the “Defendants”), and embodies the terms and conditions of the settlement of the above-captioned consolidated action (the “Action”).1 Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever compromise, settle, release, resolve, and dismiss with prejudice the Action and all claims asserted therein against Defendants.