STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • December 7th, 2005 • Kaiser Group Holdings Inc • Hazardous waste management • Delaware
This Stipulation and Agreement of Settlement (the “Agreement”) is submitted pursuant to Rules 7023 and 9019 of the Federal Rules of Bankruptcy Procedure. Subject to the approval of the Bankruptcy Court, this Agreement is entered into between and among the following parties: (i) James D. Pippin, on behalf of himself and the Class of ICT Spectrum Bankruptcy Claimants (1) (the “Class”), by and through his counsel, and (ii) Kaiser Group Holdings, Inc. (“Holdings”), and (iii) Kaiser Group International, Inc. (“Kaiser”) and its affiliated debtors(2) and debtors in possession (collectively with Kaiser, the “Debtors”).
