0001193125-18-089400 Sample Contracts

SETTLEMENT AGREEMENT
Escrow Agreement • March 21st, 2018 • Verso Corp • Paper mills • New York

THIS SETTLEMENT AGREEMENT (the “Agreement”) is entered into by and between Verso Corporation (as the sole member of the Coalition for Fair Paper Imports) (hereinafter referred to as “Petitioner”) and (1) Port Hawkesbury Paper Limited Partnership, Port Hawkesbury Paper Inc., Pacific West Commercial Corporation, Port Hawkesbury Paper Holdings Ltd., Port Hawkesbury Investments Ltd., 6879900 Canada Inc., Port Hawkesbury Paper GP Ltd., and PHP Sales Services (US) LLC (collectively, “Port Hawkesbury”); and (2) Irving Paper Limited (“Irving”). Port Hawkesbury and Irving are hereinafter referred to as a group as “Respondents” or individually by name or as “each Respondent” or “individual Respondent.” Also, Petitioner and Respondents are hereinafter referred to as a group as “the Parties” or as individuals as “such Party.”

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