Proposed Stipulation of Settlement and Release of Certain Class Action and Individual ClaimsStipulation of Settlement and Release • August 25th, 2006 • Anntaylor Stores Corp • Retail-women's clothing stores
This Stipulation of Settlement and Release of Certain Class Action and Individual Claims (“Stipulation” or “Settlement”) is made and entered into by and between Defendants AnnTaylor Retail, Inc. and AnnTaylor Stores Corporation (collectively, the “Defendants” or “AnnTaylor”), on one hand, and Plaintiffs Melissa Laykin, Naoko So, and Amanda Watson (collectively, the “Individual Plaintiffs”), on their own behalf and on behalf of a Class (as defined herein below) to be certified on a provisional basis for settlement purposes only, on the other hand. The Individual Plaintiffs and Defendants are collectively referred to as the “Parties.” (Capitalized terms shall have the meanings set forth in Section II or elsewhere in this Stipulation.)
