CLASS SETTLEMENT AGREEMENTClass Settlement Agreement • November 10th, 2016 • Delaware
Contract Type FiledNovember 10th, 2016 JurisdictionThis Class Settlement Agreement is made and entered into as of the date it is fully executed below by and between the putative representative Plaintiff WANLAND & ASSOCIATES, INC. (“Plaintiff”) in Wanland & Associates, Inc. v. Nortel Networks Corp., et al., United States District Court for the District of New Jersey, Case No. 3:05-cv-01191-MLC- TJB, which action was originally filed in the Superior Court of the State of New Jersey for the County of Ocean under Civil Case No. OCN-L-2803-04, and which is now stayed before the United States Bankruptcy Court for the District of New Jersey as Adversary Proceeding Case No. 05-02439-RG, under the bankruptcy case NORVERGENCE, Inc. Bankruptcy Proceeding, Case No. 04-32079 (collectively, the “Wanland Litigation”), on behalf of itself and the putative class members, on the one hand, and Defendants NORTEL NETWORKS LIMITED (“NNL”) and NORTEL NETWORKS INC. (“NNI”) (all parties, at times, collectively, the “Parties”). Schnader Harrison Segal & Lewis L