STIPULATION OF SETTLEMENTBorgwarner Inc • July 13th, 2022 • Motor vehicle parts & accessories
This Stipulation of Settlement, dated May 19, 2022 (this "Stipulation"), is made and entered into by and among the following Settling Parties, by and through their respective counsel of record: (i) stockholders Don David Price, Maria Nyiradi, and Peter Wahler ("Stockholders"), individually and derivatively on behalf of nominal defendant BorgWarner Inc. ("BorgWarner" or the "Company"); (ii) Alexis P. Michas, Dennis C. Cuneo, Michael S. Hanley, Joseph F. Fadool, Brady D. Ericson, and Frederic B. Lissalde (collectively, the "Individual Defendants"); and (iii) nominal defendant BorgWarner (together with the Individual Defendants, "Defendants"). This Stipulation is intended by the Settling Parties1 to fully, finally, and forever resolve, discharge, and settle the Released Claims, subject to the terms and conditions set forth herein.
