AMENDED SETTLEMENT AGREEMENTSettlement Agreement • October 7th, 2011
Contract Type FiledOctober 7th, 2011This Amended Settlement Agreement (the “Amended Agreement” or the “Amended Settlement”) is entered into by and between Mark A. Arthur and Cirilo Martinez (together, “Arthur Plaintiffs”), along with Pari Najafi (“Najafi”) and Heather McCue (“McCue”), for themselves and the settlement class, on the one hand, and Sallie Mae, Inc. (“Sallie Mae”), on the other hand, in the action entitled Mark A. Arthur, Cirilo Martinez, Pari Najafi, and Heather McCue v. Sallie Mae, Inc., United States District Court for the Western District of Washington (the “Court”), Case No. C10-0198 JLR (the “Action”). This Amended Agreement follows the original September 2, 2010 settlement agreement (the “Original Agreement” or the “Original Settlement”), preliminarily approved by the Court on September 14, 2010, and multiple in- person mediation sessions before the Honorable Edward I. Infante (Ret.), and has been amended to reflect the terms of the parties’ August 3, 2011 Memorandum of Understanding (“MOU”).