Common Contracts

STIPULATION AND AGREEMENT OF SETTLEMENT

Stipulation and Agreement of Settlement • March 5th, 2020 • Missouri

• Contract Type
  Stipulation and Agreement of Settlement
• Filed
  March 5th, 2020
• Jurisdiction
  Missouri

This Stipulation and Agreement of Settlement, dated as of March 5, 2020 (the “Stipulation”) is entered into between (a) Lead Plaintiff Louisiana Sheriffs’ Pension & Relief Fund (“Lead Plaintiff”), on behalf of itself and the Settlement Class (defined below); and (b) defendant Centene Corporation (“Centene” or the “Company”) and defendants Michael F. Neidorff and Jeffrey A. Schwaneke (the “Individual Defendants” and, with Centene, “Defendants”), by and through their counsel of record, and embodies the terms and conditions of the settlement of the above-captioned 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, discharge and dismiss with prejudice the Action and all Released Plaintiffs’ Claims (defined below).