STIPULATION AND AGREEMENT OFStipulation and Agreement of Settlement • July 2nd, 2020
Contract Type FiledJuly 2nd, 2020This Stipulation and Agreement of Settlement, dated July 2, 2020 (the “Stipulation”), is made and entered into by and among: (i) Lead Plaintiff Treasure Finance Holding Corp. and plaintiff Marcia Goldberg (“Plaintiffs”) (on behalf of themselves and each Settlement Class Member), by and through their counsel of record in the Litigation; and (ii) Defendants Graña y Montero S.A.A. (“Graña y Montero”) and Monica Miloslavich Hart (“Defendants”), by and through their counsel of record in the Litigation.1 The Stipulation is intended to fully, finally, and forever compromise, release, resolve, discharge, settle and dismiss with prejudice the Litigation and the Released Claims, subject to the approval of the Court and the terms and conditions set forth in this Stipulation.