Voluntary Dismissal and Settlement Agreement Sample Contracts

VOLUNTARY DISMISSAL AND SETTLEMENT AGREEMENT
Voluntary Dismissal and Settlement Agreement • January 13th, 2012 • Ohio

This Settlement and Voluntary Dismissal Agreement (hereinafter, “Agreement”) is made and entered into this 3rd day of January 2012, by and between Bruce Bradley, Dean Brayiannis, Michael Cappuccino, Peter Foti, Duke Greenstein, John Howard, Dale McNeill, James William Sproule, Robert Rochietti-Valle, Tony Vallecoccia, and Fred Zickmantel (collectively, the “Individual Settling Parties”), together with Domfoam International Inc. (“Domfoam”), Valle Foam Industries (1995) Inc. (“Valle Foam”), and A-Z Sponge & Foam Products Ltd. (“A-Z”, and together with Domfoam and Valle Foam, the “Voluntary Dismissal Defendants”) and Class Plaintiffs, individually and on behalf of a putative class of purchasers of polyurethane foam or polyurethane foam products (together, “polyurethane foam”) directly from any Defendants named in the above-captioned action (the “Class Action” or the “Action”).

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