STIPULATION AND AGREEMENT OF SETTLEMENTSettlement Agreement • July 12th, 2016 • Lumber Liquidators Holdings, Inc. • Retail-lumber & other building materials dealers
This Stipulation and Agreement of Settlement, dated as of June 15, 2016 (the “Stipulation”), is entered into between (a) Gregg Kiken, Keith Foster, David Lorenzo and Charles Hickman (collectively “Lead Plaintiffs”), on behalf of themselves and the Settlement Class (defined below); and (b) defendant Lumber Liquidators Holdings, Inc. (“Lumber Liquidators”), and defendants Thomas D. Sullivan, Robert M. Lynch, Daniel E. Terrell and William K. Schlegel (collectively, the “Individual Defendants,” and, together with Lumber Liquidators, the “Defendants”) by and through their respective undersigned counsel, and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”).1 Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever compromise, settle, release, resolve, and dismiss with prejudice the Action and all claims asserted therein against Defendants.
