STIPULATION AND AGREEMENT OF COMPROMISE, SETTLEMENT, AND RELEASEDelaware • May 8th, 2020
Jurisdiction FiledMay 8th, 2020This Stipulation and Agreement of Compromise, Settlement, and Release (this “Stipulation”), dated May 8, 2020, is entered into by and between (i) lead plaintiff Mark Jacobs (“Plaintiff” or “Jacobs”), on his own behalf and on behalf of the Class,1 (ii) defendant D. Ronald Yagoda (“Yagoda” and, together with defendant Phillip O. Elbert (“Elbert”), the “Special Committee”), (iii) defendants James Rustin Roach (“Roach”) and Michael R. Hill (“Hill,” and, together with Roach, the “Management Directors”), and (iv) defendants Philip A. Falcone (“Falcone”), Keith M. Hladek (“Hladek”), Paul Voigt (“Voigt”), and HC2 Holdings, Inc. (“HC2”) (collectively, the “HC2 Defendants,” and along with the Special Committee and Management Directors, the “Defendants,” and together with Plaintiff, the “Parties”), in the action captioned Schuff International, Inc. Stockholders Litigation, Consol. C.A. No. 10323-VCZ (the “Action”), all by and through their respective undersigned counsel.