MODIFIED SETTLEMENT AGREEMENT AND RELEASEModified Settlement Agreement and Release • November 13th, 2015 • California
This Modified Settlement Agreement and Release (“Agreement” or “Settlement Agreement”) is made and entered into this 13th day of November, 2015, by and among (1) Plaintiffs (as defined in Paragraph 27), for themselves and on behalf of the Settlement Class (as defined in Paragraph 40), and (2) Sony Pictures Entertainment Inc. (“SPE”), and subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. This agreement supersedes and replaces the Settlement Agreement and Release dated October 19, 2015 entered into between Plaintiffs and SPE. Plaintiffs and SPE enter into this agreement by and through their respective counsel. As provided herein, SPE, Class Counsel (as defined in Paragraph 12), and Plaintiffs hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against SPE in the action titled Cor
