0000066740-23-000073 Sample Contracts

COMBAT ARMS SETTLEMENT AGREEMENT FOR WAVE CASES MASTER SETTLEMENT AGREEMENT III
Settlement Agreement • August 29th, 2023 • 3m Co • Surgical & medical instruments & apparatus • New York

This Settlement Agreement for Wave Cases (the “Wave Settlement” or “MSA III”) dated August 29, 2023, between (1) 3M Company (“3M”) and Aearo Technologies LLC, an acquired subsidiary of 3M, along with 3M Occupational Safety, Aearo Holding LLC, Aearo Intermediate LLC, and Aearo LLC, collectively (“Aearo”), and along with 3M, collectively (“Defendants”); and (2) the undersigned Leadership in In re Combat Arms Earplug Products Liability Litigation, MDL No. 2885, U.S.D.C. for the Northern District of Florida (“MDL Court”); and (3) the undersigned Leadership in the Minnesota coordinated state court action pending in the 4th Judicial District, County of Hennepin, Minnesota, File No. 27-CV-19-19916 (“MN Court”), collectively the “Negotiating Plaintiffs’ Counsel” (“NPC”). Defendants and the NPC are each a “Party,” and, together with the NPC, are the “Parties.”

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COMBAT ARMS SETTLEMENT AGREEMENT FOR VERDICT CASES MASTER SETTLEMENT AGREEMENT II
3m Co • August 29th, 2023 • Surgical & medical instruments & apparatus • New York

This Combat Arms Settlement Agreement for Verdict Cases (“the Verdicts Settlement” or “MSA II”), dated August 29, 2023 between (1) 3M Company (“3M”) and Aearo Technologies LLC, an acquired subsidiary of 3M, along with 3M Occupational Safety, Aearo Holding LLC, Aearo Intermediate LLC, and Aearo LLC, collectively (“Aearo”), and along with 3M, collectively (“Defendants”); (2) Undersigned leadership in In re Combat Arms Earplug Products Liability Litigation, MDL No. 2885, U.S.D.C. for the Northern District of Florida (“MDL Court”); and (3) Undersigned leadership in the Minnesota coordinated state court action pending in the 4th Judicial District, County of Hennepin, Minnesota, File No. 27-CV-19-19916 (“MN Court”), collectively the “Negotiating Plaintiffs’ Counsel” (“NPC”). Defendants and all members of the NPC are each a “Party,” and, together with the NPC, are the “Parties.”

COMBAT ARMS SETTLEMENT AGREEMENT
Master Settlement Agreement • August 29th, 2023 • 3m Co • Surgical & medical instruments & apparatus • New York

This Master Settlement Agreement (“the Settlement” or the “MSA”), dated August 29, 2023 between: (1) 3M Company (“3M”) and Aearo Technologies LLC, an acquired subsidiary of 3M (“Aearo”) (collectively, along with 3M Occupational Safety, Aearo Holding LLC, Aearo Intermediate LLC, and Aearo LLC, collectively (“Aearo”), and along with 3M, collectively “Defendants”); and (2) the undersigned Plaintiffs’ Leadership in In re Combat Arms Earplug Products Liability Litigation, MDL No. 2885, U.S.D.C. for the Northern District of Florida (“MDL Court”); and (3) the undersigned Plaintiffs’ Leadership in the Minnesota coordinated state court action pending in the 4th Judicial District, County of Hennepin, Minnesota, File No. 27-CV-19- 19916 (“MN Court”), collectively the “Negotiating Plaintiffs’ Counsel” (“NPC”). Defendants and the NPC are each a “Party,” and, together with the NPC, are the “Parties.”

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