UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISIONSettlement Agreement • May 19th, 2014 • California
Contract Type FiledMay 19th, 2014 JurisdictionIT IS HEREBY STIPULATED AND AGREED, by, between, and among Rosalie Vaccarino and David Lee Tegen, individually and on behalf of the Class defined in this agreement (collectively, “Plaintiffs”), and Midland National Life Insurance Company (with its parents, subsidiary, affiliate, predecessor and successor entities, collectively, “Midland” or “Defendant”), through their respective counsel, that the proceedings in the United States District Court for the Central District of California, Western Division, captioned, Vaccarino v. Midland National Life Ins. Co., 11-CV-05858 CAS (MANx) (the “Action”), and matters raised by and related to the Action, are settled fully and finally, compromised, and dismissed on the merits, and with prejudice, on the terms and conditions set forth in this Agreement and the attached exhibits, subject to the occurrences set forth that permit Plaintiffs or Midland to terminate this Settlement, as well as the approval of the Court and entry of judgment.