Robbins Geller Rudman & Dowd Sample Contracts

JANSSEN SETTLEMENT AGREEMENT
Janssen Settlement Agreement • February 28th, 2022

This settlement agreement dated as of July 21, 2021 (the “Agreement”) sets forth the terms of settlement between and among the Settling States, Participating Subdivisions, and Janssen (as those terms are defined below). Upon satisfaction of the conditions set forth in Sections II and VIII, this Agreement will be binding on the Settling States, Janssen, and Participating Subdivisions. This Agreement will then be filed as part of Consent Judgments in the respective courts of each of the Settling States, pursuant to the terms set forth in Section VIII.

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vs.
March 5th, 2020
  • Filed
    March 5th, 2020

This Stipulation and Agreement of Settlement (the “Stipulation”) is made and entered into by and between Lead Plaintiffs Eugene Almendinger, Jeffrey Berkowitz, Debra Folk, Earle Folk, Maryann Lovelidge, and Tom Lovelidge (collectively, “Lead Plaintiffs”), on behalf of themselves and all other members of the proposed Settlement Class (defined below), on the one hand, and defendants Mutual Fund Series Trust (the “Trust”), Catalyst Capital Advisors, LLC (“Catalyst”), Northern Lights Distributors LLC (“NLD”), Jerry Szilagyi (“Szilagyi”), Tobias Caldwell (“Caldwell”), Tiberiu Weisz (“Weisz”), Bert Pariser (“Pariser”), and Erik Naviloff (“Naviloff”) (each a “Defendant” and collectively, “Defendants”), on the other, by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the Eastern District of New York (the “Court”). This Stipulation is intended by the Parties (defined below) to fully, finally, and forever resolve, discharge, a

CLASS ACTION AND FAIR FUND SERVICES AGREEMENT
Class Action and Fair Fund Services Agreement • August 4th, 2011 • Capstone Series Fund Inc • Texas

CAPSTONE ASSET MANAGEMENT COMPANY (“CAMCO”), a Delaware corporation having its principal place of business in Houston, Texas; and

DEFINITIVE CLASS SETTLEMENT AGREEMENT
October 19th, 2012
  • Filed
    October 19th, 2012

Subject to the preliminary and final approval of the Court, and as further set forth below, this Definitive Class Settlement Agreement (“Class Settlement Agreement”) is made as of the 19th day of October, 2012, by and between the Class Plaintiffs defined below, individually and as representatives of the Rule 23(b)(3) Settlement Class and the Rule 23(b)(2) Settlement Class defined below, Class Counsel defined below, and the Defendants defined below.

STIPULATION AND AGREEMENT OF ) SETTLEMENT
Stipulation and Agreement • November 11th, 2021

This Stipulation and Agreement of Settlement (together with all Exhibits hereto, the “Settlement Agreement”), dated as of November 12, 2021, which is entered into by and among: (i) Plaintiffs and Class Representatives Laborers Pension Trust Fund for Northern Nevada (“Northern Nevada”), Construction Laborers Pension Trust of Greater St. Louis (“Greater St. Louis”), and Angelica Galkin (collectively, “Plaintiffs”), on behalf of themselves and on behalf of the Class Members (as defined herein); and (ii) Settling Defendants Tom L. Ward, James D. Bennett, and Matthew K. Grubb (the “Settling Defendants,” and with the Plaintiffs, the “Settling Parties”), by and through their undersigned attorneys, states all of the terms of the settlement and resolution of this matter by the Settling Parties (as defined herein) and is intended by the Settling Parties to fully and finally release, resolve, remise, and discharge the Released Claims (as defined herein) against the Released Persons (as defined he

STIPULATION AND AGREEMENT OF
Stipulation and Agreement • May 7th, 2020

This Stipulation and Agreement of Settlement dated as of May 8, 2020 (the “Stipulation”), is made and entered into by and among: (i) District No. 9, I.A. of M & A.W. Pension Trust (on behalf of itself and each of the Class Members), by and through its counsel of record in the Litigation (as defined herein); and (ii) Defendants Lexmark International, Inc. (“Lexmark” or the “Company”), and Paul A. Rooke, David Reeder, and Gary Stromquist (the “Individual Defendants,” and collectively, with Lexmark, the “Defendants”), by and through their counsel of record in the Litigation. The Stipulation is intended to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined herein), subject to the approval of the Court and the terms and conditions set forth in this Stipulation.

STIPULATION AND AGREEMENT OF : SETTLEMENT WITH BANK OF AMERICA
Stipulation and Agreement • August 17th, 2017

This Stipulation and Agreement of Settlement (“Stipulation” or “Agreement”) is made and entered into on August 11 , 2017 (“Execution Date”), between (i) on the one hand, Plaintiffs Sheet Metal Workers Pension Plan of Northern California, KBC Asset Management NV, and Iron Workers Pension Plan of Western Pennsylvania (collectively, “Class Plaintiffs”), for themselves individually and on behalf of all Settlement Class Members as defined herein, and, (ii) on the other hand, Bank of America Corporation, Bank of America, N.A., Bank of America Merrill Lynch International Limited, Merrill Lynch International, and Merrill Lynch, Pierce, Fenner & Smith Incorporated (collectively, “Bank of America,” “BofA,” or “Settling Defendant”), by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the Southern District of New York. Class Plaintiffs and Settling Defendant are collectively referred to herein as the “Parties.” This Agreement is

SETTLEMENT AGREEMENT
Settlement Agreement • November 18th, 2020

This Settlement Agreement dated January 30, 2019 (the “Stipulation” or the “Settlement Agreement”) embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Lead Plaintiff Construction Laborers Pension Trust of Greater St. Louis (“Pension Trust” or “Lead Plaintiff”) and named plaintiff Wayne County Employees’ Retirement System (“Wayne County”) (collectively, “Plaintiffs”), on behalf of themselves and each of the members of the Class, as defined in ¶¶1.3-1.4, infra, on the one hand, and

SETTLEMENT AGREEMENT
Settlement Agreement • April 28th, 2021

This Settlement Agreement dated March 7, 2011 (the “Stipulation” or the “Settlement Agreement”), embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties:1 (i) the Lead Plaintiffs (on behalf of themselves and each of the members of the Settlement Class), and (ii) the Defendants, by and through their counsel of record in the above-referenced consolidated class action litigation pending in the United States District Court for the Southern District of New York (the “Action”). The Stipulation is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims (including Unknown Claims), upon and subject to the terms and conditions hereof and subject to the approval of the Court.

Contract
Class Action and Fair Fund Services Agreement • August 28th, 2012 • Steward Funds, Inc. • Texas
STIPULATION OF SETTLEMENT
Stipulation of Settlement • September 9th, 2020

This Stipulation of Settlement dated March 16, 2020 (the “Stipulation”), is made and entered into by and among: (i) Lead Plaintiff Trigon Trading Pty. Ltd. (“Trigon” or “Federal Lead Plaintiff”), and plaintiffs Pumaro LLC, Artiom Frunze, Hayden Hsiung, and Gijs Matser (collectively, the “Federal Plaintiffs”), on behalf of themselves and the other members of the Settlement Class (as defined herein), by and through their counsel of record in the Federal Litigation (as defined herein); (ii) plaintiff Andrew Baker (the “State Plaintiff”) (together with the Federal Plaintiffs, “Plaintiffs”) on behalf of himself and the other members of the Settlement Class, by and through his counsel of record in the State Litigation (as defined herein); and (iii) Defendants Dynamic Ledger Solutions, Inc. (“DLS” or the “Company”), Arthur Breitman and Kathleen Breitman (collectively the “DLS Defendants”) and Tezos Stiftung (the “Tezos Foundation”) (together with the DLS Defendants, “Defendants”), by and thro

Stipulation for settlement form california
Stipulation and Agreement • July 1st, 2020

Exhibit 99.2 STIPULATION AND AGREEMENT OF SETTLEMENT This Stipulation and Agreement of Settlement (“Stipulation”) dated May 4, 2011, is made and entered into by and among the following Parties: (i) City of Pontiac Policeman’s and Fireman’s Retirement System and Robert B. Minich (“Plaintiffs”), individually and derivatively on behalf of Fossil, Inc. (“Fossil” or the “Company”); (ii) Tom Kartsotis, Kosta N. Kartsotis, Michael W. Barnes, Jal S. Shroff, Alan J. Gold, Kenneth W. Anderson, Donald J. Stone, Michael Steinberg, Caden Wang, Richard H. Gundy, Mark D. Quick, Randy S. Kercho, Michael L. Kovar, Thomas R. Tunnell, Randy S. Hyne, Stephen Bock, and Junichi Hattori (the “Individual Defendants”); and (iii) Fossil, by and through its counsel of record in the Action. This Stipulation is intended by the Parties to fully, finally, and forever compromise, resolve, discharge, and settle the Released Claims and dismiss the Action with prejudice, upon the terms and subject to the conditions set

SETTLEMENT AGREEMENT
Settlement Agreement • January 30th, 2022 • New York

This SETTLEMENT AGREEMENT (as defined herein) is between: (i) the National Hockey League, the NHL Board of Governors, and NHL Enterprises, Inc. (hereinafter collectively the “NHL”), on the one hand, and (ii) the “Plaintiffs’ Counsel” (as defined herein) on the other hand (each attorney and firm of Plaintiffs’ Counsel and each entity of NHL is a “Party” and collectively are the “Parties”).

SETTLEMENT AGREEMENT AND GENERAL RELEASE
New York • April 24th, 2023
  • Jurisdiction
  • Filed
    April 24th, 2023

Representative plaintiff Dr. D. Joseph Kurtz (“Plaintiff”), on behalf of himself and all Settlement Class Members (defined below), on the one hand, and defendant Costco Wholesale Corporation (“Costco” or “Defendant”) and non-party Nice-Pak Products, Inc. (“Nice-Pak”) (collectively, the “Settling Parties”), on the other hand, hereby enter into this stipulation of settlement and general release (“Settlement Agreement”), subject to approval of the Court.

STIPULATION AND AGREEMENT OF COMPROMISE AND SETTLEMENT
Stipulation and Agreement • October 5th, 2011

This Stipulation and Agreement of Compromise and Settlement (the “Stipulation”), dated October 5, 2011, which is entered into by and among (i) Plaintiff NECA-IBEW Pension Fund (The Decatur Plan) (“Lead Plaintiff”), on its own behalf and on behalf of the Settlement Class (as defined herein); (ii) Kohlberg Kravis Roberts & Co. L.P. (“KKR”), Vestar Capital Partners (“Vestar”), Centerview Capital, L.P. (named in the Action (as defined below) as Centerview Partners, “Centerview”), Blue Acquisition Group, Inc., and Blue Merger Sub Inc. (collectively, the “Sponsors”); (iii) Barclays Capital Inc. (“Barclays”); (iv) Richard G. Wolford, Samuel H. Armacost, Timothy G. Bruer, Mary R. Henderson, Victor L. Lund, Terence D. Martin, Sharon L. McCollam, Joe L. Morgan, and David R. Williams (the “Director Defendants”); and (v) Del Monte Corporation, as successor-in-interest to Del Monte Foods Company (together, the “Del Monte Companies” and collectively, with the Sponsors, Barclays, and the Director Def

EXHIBIT B
Settlement Agreement • June 10th, 2014 • Massachusetts

This Settlement Agreement, dated June 10, 2014 (the “Agreement”), is entered into by and among Scott + Scott, Attorneys at Law, LLP, Robbins Geller Rudman & Dowd LLP, and Robins, Kaplan, Miller & Ciresi L.L.P., on behalf of plaintiffs Kirk Dahl, Police and Fire Retirement System of the City of Detroit, City of Omaha Police and Fire Retirement System, and Michael Wojno, as executor for the estate of Robert Zimmerman and all others similarly situated, on the one hand; and defendant The Goldman Sachs Group, Inc. (on behalf of its predecessors, successors, and all past and present subsidiaries, affiliates and investor funds) (“Goldman Sachs”), on the other hand. Goldman Sachs and Named Plaintiffs (as defined below) are referred to herein individually as a “Party” and collectively as the “Parties.”

STIPULATION OF SETTLEMENT
Stipulated Settlement Agreement • September 23rd, 2019

This stipulated Settlement Agreement dated September 23, 2019 (the “Stipulation” or the “Settlement Agreement”) embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Plumbers and Pipefitters National Pension Fund (“Plumbers and Pipefitters”), United Association Local Union Officers & Employees’ Pension Fund (the “UA Fund”), and the Department of the Treasury of the State of New Jersey and its Division of Investment (“New Jersey”) (collectively, Plumbers and Pipefitters, the UA Fund, and New Jersey are hereinafter referred to as “Lead Plaintiffs” or “Plaintiffs”), on behalf of themselves and each of the Class Members, and (ii) Defendants Trinity Industries, Inc. (“Trinity” or the “Company”), Timothy R. Wallace, James E. Perry, and Gregory B. Mitchell (collectively, “Defendants”), by and through their counsel of record in the above-captioned consolidated litigation (the “Action”) pending in the United States District Court for the

STIPULATION AND AGREEMENT OF
Stipulation and Agreement • April 25th, 2021

This Stipulation and Agreement of Settlement dated as of April 22, 2019 (the “Stipulation” or the “Settlement”), is made and entered into by and among: (i) plaintiff Afshin Galestan (“Plaintiff”), by and through his counsel of record in the Litigation (as defined herein); and (ii) defendants OneMain Holdings, Inc. (“OneMain” or the “Company”), Jay N. Levine and Scott T. Parker (“Individual Defendants,” and, with OneMain, “Defendants”), by and through their counsel of record in the Litigation. The Stipulation is intended to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined herein), subject to the approval of the Court and the terms and conditions set forth in this Stipulation.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION
Settlement Agreement • April 1st, 2015

This Settlement Agreement dated as of April 1, 2015 (the “Stipulation” or the “Settlement Agreement”), entered into pursuant to Rule 23 of the Federal Rules of Civil Procedure, embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties:

STIPULATION AND AGREEMENT OF
Stipulation and Agreement • April 23rd, 2019

This Stipulation and Agreement of Settlement dated as of April 22, 2019 (the “Stipulation” or the “Settlement”), is made and entered into by and among: (i) plaintiff Afshin Galestan (“Plaintiff”), by and through his counsel of record in the Litigation (as defined herein); and (ii) defendants OneMain Holdings, Inc. (“OneMain” or the “Company”), Jay N. Levine and Scott T. Parker (“Individual Defendants,” and, with OneMain, “Defendants”), by and through their counsel of record in the Litigation. The Stipulation is intended to fully, finally, and forever resolve, discharge, and settle the Released Claims (as defined herein), subject to the approval of the Court and the terms and conditions set forth in this Stipulation.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION
Action Settlement Agreement • February 27th, 2020 • Georgia

This Class Action Settlement Agreement, dated March 6, 2020 (the “Settlement Agreement”), is made and entered into by and among: (i) Plaintiff Diego Cervantes (“Plaintiff”) (on behalf of himself and each Class Member), by and through his counsel of record in the Action; and (ii) Invesco Holding Company (US), Inc. (“Invesco” or the “Company”), Invesco LTD., Invesco National Trust Company, Invesco Advisers, Inc., Invesco Benefits Plan Committee, Suzanne Christensen, John Coleman, Washington Dender, Peter Gallagher, David Genova, Douglas Sharp, Ben Utt, Gary Wendler, Kevin M. Carome, Loren M. Starr, and John Does 1-20 (collectively, “Defendants”), by and through their counsel of record in the Action.1 The Settlement Agreement is intended to fully, finally, and forever resolve, discharge, and settle the released claims, subject to the approval of the Court and the terms and conditions set forth in this Stipulation.

SETTLEMENT AGREEMENT
Settlement Agreement • November 2nd, 2020

This Settlement Agreement dated June 14, 2017, 2017 (the “Stipulation” or the “Settlement Agreement”) embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Lead Plaintiff the National Shopmen Pension Fund (“NSPF” or “Lead Plaintiff”), on behalf of itself and each of the members of the Class, as defined in ¶¶1.3-1.4, infra, on the one hand, and (ii) Defendants J.C. Penney Company, Inc. (“JCPenney”), Myron E. Ullman, III, and Kenneth H. Hannah (collectively, “Defendants” ), on the other hand, by and through their counsel of record in the above-captioned consolidated litigation pending in the United States District Court for the Eastern District of Texas (the “Action”). The Stipulation is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims, upon and subject to the terms and conditions hereof and subject to the approval of the Court. Throughout this Stipulation, all capi

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SETTLEMENT AGREEMENT
Settlement Agreement • March 19th, 2014

This Settlement Agreement, dated March 19, 2014 (the “Stipulation” or the “Settlement Agreement”), submitted pursuant to Rule 23 of the Federal Rules of Civil Procedure and Rule 408 of the Federal Rules of Evidence, embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Lead Plaintiffs Jeff Schram and Linda Schram (“Lead Plaintiffs”), on behalf of themselves and each of the members of the Class, as defined in ¶¶1.3-1.4, infra, on the one hand, and (ii) Defendant CNinsure Inc. (“Defendant” or “CNinsure” or the “Company”), on the other hand, by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the Southern District of New York (the “Action”).1 This Stipulation is intended by the Settling Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims, upon and subject to the terms and conditions hereof and subject to the approval of the Co

SETTLEMENT AGREEMENT
Settlement Agreement • November 11th, 2020

This Settlement Agreement dated as of January 15, 2016 (the “Stipulation” or the “Settlement Agreement”), entered into pursuant to Rule 23 of the Federal Rules of Civil Procedure, embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Lead Plaintiff Firerock Global Opportunity Fund LP (“Lead Plaintiff”), on behalf of itself and each of the members of the Class, as defined in ¶1.3, infra, on the one hand, and (ii) Defendants Rubicon Technology, Inc. (“Rubicon” or the “Company”), Raja M. Parvez, William F. Weissman, Don N. Aquilano, Donald R. Caldwell, Michael E. Mikolajczyk, Raymond J. Spencer, Canaccord Genuity Inc. (“Canaccord”), and D.A. Davidson & Co. (“D.A. Davidson”) (with Canaccord Genuity, the “Underwriter Defendants”) (all collectively, the “Defendants”) on the other hand, by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the Northern District of Illin

ADDENDUM TO AMENDED SETTLEMENT AGREEMENT
Settlement Agreement • March 12th, 2021

This Addendum to the Amended Settlement Agreement dated May 4, 2015 (the “Addendum”) is made and entered into by and among the following parties (collectively, the “Parties”): (a) SS Body Armor I, Inc., formerly known as Point Blank Solutions, Inc., on behalf of itself and its affiliated debtors and debtors in possession SS Body Armor II, Inc., SS Body Armor III, Inc. and PBSS, LLC in the chapter 11 proceeding pending in the United States Bankruptcy Court for the District of Delaware captioned In re SS Body Armor I, Inc., et al., Case No. 10-11255 (CSS); (b) the lead plaintiffs in the consolidated securities class action captioned In re DHB Industries, Inc. Class Action Litigation, Case No. 05-cv-04296 (E.D.N.Y.), on behalf of themselves and all members of the class previously certified in the Class Action; (c) Plaintiffs’ counsel in the Class Action, namely Robbins Geller Rudman & Dowd LLP and Labaton Sucharow LLP; and (d) plaintiff’s counsel in the consolidated derivative action capt

AMENDED AND RESTATED CLASS ACTION AND FAIR FUND SERVICES AGREEMENT
Class Action and Fair Fund Services Agreement • August 28th, 2020 • Steward Funds, Inc. • Texas

THIS AMENDED AND RESTATED CLASS ACTION AND FAIR FUND SERVICES AGREEMENT (“Agreement”), made the 9th day of December, 2019, by and between CROSSMARK GLOBAL INVESTMENTS, INC. (“CROSSMARK”), a Delaware corporation having its principal place of business in Houston, Texas, and STEWARD FUNDS, INC. (“SFI”), a Maryland corporation having its principal place of business in Houston, Texas. SFI adopts this Agreement on behalf of all current and future series of SFI (each a “Fund”).

JANSSEN SETTLEMENT AGREEMENT
Janssen Settlement Agreement • July 30th, 2021

This settlement agreement dated as of July 21, 2021 (the “Agreement”) sets forth the terms of settlement between and among the Settling States, Participating Subdivisions, and Janssen (as those terms are defined below). Upon satisfaction of the conditions set forth in Sections II and VIII, this Agreement will be binding on the Settling States, Janssen, and Participating Subdivisions. This Agreement will then be filed as part of Consent Judgments in the respective courts of each of the Settling States, pursuant to the terms set forth in Section VIII.

JANSSEN SETTLEMENT AGREEMENT
Janssen Settlement Agreement • July 30th, 2021

This settlement agreement dated as of July 21, 2021 (the “Agreement”) sets forth the terms of settlement between and among the Settling States, Participating Subdivisions, and Janssen (as those terms are defined below). Upon satisfaction of the conditions set forth in Sections II and VIII, this Agreement will be binding on the Settling States, Janssen, and Participating Subdivisions. This Agreement will then be filed as part of Consent Judgments in the respective courts of each of the Settling States, pursuant to the terms set forth in Section VIII.

AMENDED AND RESTATED CLASS ACTION AND FAIR FUND SERVICES AGREEMENT
Class Action and Fair Fund Services Agreement • September 29th, 2017 • Steward Funds, Inc. • Texas

THIS CLASS ACTION AND FAIR FUND SERVICES AGREEMENT (this “Agreement”), made the 12th day of January, 2012, as amended February 14, 2017, and further amended September 8, 2017, is by and between CROSSMARK CONSULTING, LLC (Crossmark Consulting), a Texas limited liability company having its principal place of business in Houston, Texas, and STEWARD FUNDS, INC. (“SFI”), a Maryland corporation having its principal place of business in Houston, Texas, acting on behalf of its series portfolios listed on Schedule A hereto (each a "Fund”).

SETTLEMENT AGREEMENT
Settlement Agreement • March 12th, 2020

This Settlement Agreement dated March 12, 2020 (the “Stipulation” or the “Settlement Agreement”), submitted pursuant to Rule 23 of the Federal Rules of Civil Procedure and Rule 408 of the Federal Rules of Evidence, embodies a settlement (the “Settlement”) made and entered into by and among the following Settling Parties: (i) Lead Plaintiffs City of Pontiac General Employees’ Retirement System, Oklahoma Police Pension & Retirement System, and City of Omaha Police & Fire Retirement System (“Lead Plaintiffs”), on behalf of themselves and each of the members of the Class, as defined in ¶¶1.3-1.4, infra, on the one hand, and (ii) Defendants Camping World Holdings, Inc. (“Camping World” or the “Company”), Marcus A. Lemonis, Thomas F. Wolfe, Brent L. Moody, Stephen Adams, Crestview Partners II GP, L.P., Crestview Advisors, L.L.C., Andris A. Baltins, Brian P. Cassidy, Mary J. George, Daniel G. Kilpatrick, Howard A. Kosick, Jeffrey A. Marcus, K. Dillon Schickli, Goldman Sachs & Co. LLC, J.P. Mo

EXHIBIT A
Settlement Agreement • June 10th, 2014 • Massachusetts

This Settlement Agreement, dated June 9, 2014 (the “Agreement”), is entered into by and among Scott + Scott, Attorneys at Law, LLP, Robbins Geller Rudman & Dowd LLP, and Robins, Kaplan, Miller & Ciresi L.L.P., on behalf of plaintiffs Kirk Dahl, Police and Fire Retirement System of the City of Detroit, City of Omaha Police and Fire Retirement System, and Michael Wojno, as executor for the estate of Robert Zimmerman (collectively, the “Named Plaintiffs”) and a settlement class of all others similarly situated, as more fully defined in paragraph 2 below, on the one hand; and defendant Bain Capital Partners, LLC (including its predecessors, successors, and all past and present directors, managing directors, partners, officers, employees, and affiliates) (“Bain Capital”), on the other hand. Bain Capital and the Named Plaintiffs are referred to herein individually as a “Party” and collectively as the “Parties.”

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement • February 5th, 2014

This stipulation and agreement of settlement (the “Stipulation”) is made and entered into by and between Lead Plaintiff, the Commonwealth of Massachusetts Pension Reserves Investment Trust (“Lead Plaintiff”) and named plaintiff David Wagner (collectively “Plaintiffs”), on behalf of themselves and the proposed Settlement Class (defined below), on the one hand, and Massey Energy Company (n/k/a Alpha Appalachia Holdings, Inc.) (“Massey” or the “Company”), Donald L. Blankenship, Baxter F. Phillips, Jr., Eric B. Tolbert, J. Christopher Adkins, Dan R. Moore, E. Gordon Gee, Richard M. Gabrys, James B. Crawford, Robert H. Foglesong, Stanley C. Suboleski and Lady Barbara Thomas Judge (collectively, the “Defendants”), and Alpha Natural Resources, Inc. (“ANR”), on the other hand.

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement • March 7th, 2022

This Stipulation and Agreement of Settlement, dated March 4, 2022 (the “Stipulation”), is entered into between (a) Lead Plaintiff and Class Representative Freedman Family Investments LLC, on behalf of itself and the plaintiff class certified by the Court (the “Class,” as defined in

Contract
October 13th, 2020
  • Filed
    October 13th, 2020
CLASS SETTLEMENT AGREEMENT
July 13th, 2012
  • Filed
    July 13th, 2012

Subject to the preliminary and final approval of the Court, and as further set forth below, this Class Settlement Agreement is made as of the day of , 2012, by and between the Class Plaintiffs defined below, individually and as representatives of the Rule 23(b)(3) Settlement Class and the Rule 23(b)(2) Settlement Class defined below, Class Counsel defined below, and the Defendants defined below.

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