AMENDED SETTLEMENT AGREEMENTSettlement Agreement • April 20th, 2010
Contract Type FiledApril 20th, 2010This Amended Settlement Agreement, dated as of April 20, 2010 (the “Settlement Agreement”), is made and entered into by and among the following Settling Parties (as defined further in ¶1.24 hereof) to the above-captioned consolidated action: (i) Mark Dearman, Anthony DeBiseglia, Matthew Marr, Adam Kline, Greg Besinger, Collin L. McGeary, Javier Tunon, and Jean-Sebastien Elie (the “Representative Plaintiffs”), individually and on behalf of the Settlement Class (as defined herein in ¶1.20), by and through Ben Barnow, Barnow and Associates, P.C., and Robert M. Rothman, Robbins Geller Rudman & Dowd LLP (together, “Settlement Class Counsel”); and (ii) The Gillette Company (“Gillette”), by and through its counsel of record, Harvey J. Wolkoff, Ropes & Gray LLP. The Settlement Agreement is intended by the Settling Parties fully, finally, and forever to resolve, discharge, and settle the Released Claims (as defined below), upon and subject to the terms and conditions hereof.