AMENDED SETTLEMENT AGREEMENTSettlement Agreement • October 1st, 2015
Contract Type FiledOctober 1st, 2015This Amended Settlement Agreement, dated August 27, 2015 (the “Stipulation” or the “Settlement Agreement”), submitted pursuant to Rule 23 of the Federal Rules of Civil Procedure and Rule 408 of the Federal Rules of Evidence, embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Lead Plaintiff National Elevator Industry Pension Fund (“Lead Plaintiff”), individually and on behalf of the proposed Class, as defined in ¶¶1.3-1.4, infra, on the one hand, and (ii) Defendants Baxter International Inc. (“Baxter” or the “Company”), Robert L. Parkinson, Jr., Robert M. Davis, and Mary Kay Ladone (collectively, “Defendants”), on the other hand, by and through their counsel of record in the above-captioned consolidated litigation pending in the United States District Court for the Northern District of Illinois (the “Action”). This Stipulation is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the