UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISIONStipulation and Agreement of Settlement • February 14th, 2014 • Broadwind Energy, Inc. • Nonferrous foundries (castings)
This Stipulation of Settlement dated January 10, 2014 (the “Stipulation”), is made and entered into by and among the following Parties (as defined further in ¶1.12 hereof), each by and through their respective counsel: (i) plaintiffs Bonnie Mitchell and Michael Friedman (“Plaintiffs”), on behalf of themselves and derivatively on behalf of Broadwind Energy, Inc. (“Broadwind” or the “Company”); and (ii) nominal defendant Broadwind. This Stipulation is intended by the Parties to fully, finally and forever resolve, discharge and settle the Released Claims (as defined in ¶1.18 hereof), upon and subject to the terms and conditions hereof. Capitalized terms not otherwise defined herein shall have the definitions set forth in ¶¶1.1-1.24 below.
