SETTLEMENT AGREEMENT BETWEEN BONDHOLDER PLAINTIFFS AND THE NORINCHUKIN BANKSettlement Agreement • September 27th, 2021
Contract Type FiledSeptember 27th, 2021This Settlement Agreement is made and entered into on September 27, 2021 (the “Execu- tion Date”), between Plaintiffs Ellen Gelboim and Linda Zacher (collectively, the “Bondholder Plaintiffs”), individually and on behalf of the Bondholder Class in the Bondholder Action, and defendant The Norinchukin Bank (“Norinchukin”), by and through Bondholder Plaintiffs’ Counsel and Norinchukin’s Counsel, respectively. This Agreement is intended by the Parties to fully, fi- nally, and forever resolve, discharge, and settle the Released Claims, upon and subject to the terms and conditions hereof.