STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • December 7th, 2015
Contract Type FiledDecember 7th, 2015This Stipulation and Agreement of Settlement, dated as of December 7, 2015 (the “Stipulation”) is entered into by and among (a) plaintiffs City of Providence, Central Laborers’ Pension Fund, Massachusetts Laborers’ Annuity Fund, New England Teamsters & Trucking Industry Pension Fund, and Oklahoma Police Pension & Retirement System (collectively, “Plaintiffs”), on behalf of themselves and the Class (defined below); (b) defendants David H. Murdock (“Murdock”), C. Michael Carter (“Carter”), David A. DeLorenzo (“DeLorenzo”), and DFC Holdings, LLC (“DFC Holdings”) (collectively, and together with Deutsche Bank AG, New York Branch and Deutsche Bank Securities Inc., “Defendants”), by and through their respective undersigned counsel, and embodies the terms and conditions of the settlement of the above-captioned consolidated stockholder class action lawsuit (the “Litigation”).1 Subject to the approval of the Court of Chancery of the State of Delaware (the “Court of Chancery” or the “Court”) and