Class Settlement AgreementClass Settlement Agreement • November 17th, 2011 • Wisconsin
Contract Type FiledNovember 17th, 2011 JurisdictionSubject to approval, by the United States District Court for the Eastern District of Wisconsin (the “Court”), this Class Settlement Agreement (“Agreement”) is made and entered into by and among Plaintiffs Alan M. Downes and Terry P. Kumbera (“Plaintiffs” or “Named Plaintiffs”), individually and on behalf of a proposed Class (the “Class,” as defined below), and Defendants Wisconsin Energy Corporation Retirement Account Plan, including the Wisconsin Energy Corporation Legacy Plan (collectively, the “Plan,” as defined below) and Wisconsin Energy Corporation (“WE”) (collectively, “Defendants”).