Common Contracts

STIPULATION AND AGREEMENT OF SETTLEMENT

Settlement Agreement • November 15th, 2019 • Texas

• Contract Type
  Settlement Agreement
• Filed
  November 15th, 2019
• Jurisdiction
  Texas

This Stipulation and Agreement of Settlement, dated as of November 15, 2019 (the “Stipulation”), is entered into between (a) Lead Plaintiff Greg Hrasok (“Plaintiff”), on behalf of himself and the Class (defined below); and (b) defendants Kevin M. Fogarty, Stephen E. Tremblay (collectively, with defendant Fogarty, the “Individual Defendants”) and Kraton Corporation (“Kraton” or the “Company” and collectively, with the Individual Defendants, “Defendants”), and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”).1 Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever compromise, settle, release, resolve, and dismiss with prejudice, inter alia, the Action and all claims asserted therein.