Common use of STIPULATION AND AGREEMENT OF SETTLEMENT Clause in Contracts

STIPULATION AND AGREEMENT OF SETTLEMENT. This Stipulation and Agreement of Settlement, dated as of April 14, 2020 (the “Stipulation”) is entered into between (a) Lead Plaintiffs Xxxxxx X. Xxxx and Xxxx Xxxxxxxx (“Lead Plaintiffs”), and additional plaintiffs UFCW Local 1500 and Xxxxxx Xxxxxxxx (together with Lead Plaintiffs, “Plaintiffs”), on behalf of themselves and the Settlement Class (defined below); and (b) defendant Xxxxxx Biomet Holdings, Inc. (“ZBH” or the “Company”), defendants Xxxxx X. Xxxxxx, Xxxxxx X. Xxxxxx, Xxxxxx X. Xxxxxxxx Xx., Xxxx X. Xxxxxxx (collectively the “Officer Defendants”), and defendants Xxxxxxxxxxx X. Xxxxxx, Xxxxx X. Xxxxxxx, Xxxx X. Xxxxxx, Xxxx X. Xxxxxxxxx, Xxxxxxx X. Xxxxxxx, Xxxxx Xxxxxxxxx, Xxxxxx X. Xxxxxxxx, Xxxxxx X. Xxxxxxx, Xxxxxxx X. Xxxxxxxxx, Xxxxx X. Xxxxxxx, Ph.D., Xxxxxxx X. Xxxxxx (together with the Officer Defendants, the “Individual Defendants,” and, together with ZBH and the Officer Defendants, the “Defendants”), and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”).1 Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever 1 All terms with initial capitalization not otherwise defined herein shall have the meanings ascribed to them in ¶ 1 herein. compromise, settle, release, resolve, and dismiss with prejudice the Action and all claims asserted therein against Defendants.

STIPULATION AND AGREEMENT OF SETTLEMENT. This Stipulation and Agreement of SettlementSettlement (together with all Exhibits hereto, the “Stipulation”), dated as of April 14October 20, 2020 (the “Stipulation”) 2021, which is entered into between by and among (ai) Lead Plaintiffs Plaintiff IGC Investor Group (consisting of Lead Plaintiff members Xxxxxx X. Xxxx Xxxxxx, Xxxxxxx Xxxxxxx Xxxx, Xxxxxx Xxxxxxx Xxxx, Xxxxxxx Xxxxxxxxxx, Xxxxxxx Xxxxxxxxxx, Xxx Xxxx, and Xxxx Xxxxxxxx X. Xxxxx) (collectively, “Plaintiffs” or “Lead Plaintiffs”), individually and additional plaintiffs UFCW Local 1500 and Xxxxxx Xxxxxxxx (together with Lead Plaintiffs, “Plaintiffs”), on behalf of themselves and the Settlement Class (as defined belowherein); and (bii) defendant Xxxxxx Biomet HoldingsDefendant India Globalization Capital, Inc. (“ZBHIGC” or the “Company”), defendants Xxxxx X. Xxxxxx, Xxxxxx X. Xxxxxx, Xxxxxx X. ; and (iii) Defendants Xxx Xxxxxxx and Xxxxxxx Xxxxxxxx Xx., Xxxx X. Xxxxxxx (collectively the “Officer Defendants”), and defendants Xxxxxxxxxxx X. Xxxxxx, Xxxxx X. Xxxxxxx, Xxxx X. Xxxxxx, Xxxx X. Xxxxxxxxx, Xxxxxxx X. Xxxxxxx, Xxxxx Xxxxxxxxx, Xxxxxx X. Xxxxxxxx, Xxxxxx X. Xxxxxxx, Xxxxxxx X. Xxxxxxxxx, Xxxxx X. Xxxxxxx, Ph.D., Xxxxxxx X. Xxxxxx (together with the Officer Defendantscollectively, the “Individual Defendants,” and, together with ZBH and the Officer DefendantsIGC, the “Defendants”), by and embodies through their undersigned attorneys, states all of the terms and conditions of the settlement and resolution of this matter by the above-captioned action Settling Parties (as defined herein) and is intended by the “Action”).1 Subject Parties to fully and finally release, resolve, remise, and discharge the Released Claims (as defined herein) against the Released Parties (as defined herein), subject to the approval of the United States District Court and for the District of Maryland (“Court”). Throughout this Stipulation, all terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever 1 All terms used with initial capitalization capitalization, but not otherwise defined herein immediately defined, shall have the meanings ascribed to them in ¶ Section 1 herein. compromise, settle, release, resolve, and dismiss with prejudice the Action and all claims asserted therein against Defendantsbelow.

STIPULATION AND AGREEMENT OF SETTLEMENT. This Stipulation and Agreement of Settlement, dated as of April 14January 15, 2020 2021 (the “Stipulation”) ), is entered into between (a) Lead Plaintiffs Xxxxxx X. Xxxx and Xxxx Xxxxxxxx Plaintiff The Regents of the University of California (“Lead Plaintiffs”), and additional plaintiffs UFCW Local 1500 and Xxxxxx Xxxxxxxx (together with Lead Plaintiffs, “PlaintiffsPlaintiff”), on behalf of themselves itself and the Settlement Class (defined below); and (b) defendant defendants Xxxxxx Biomet Holdings, Inc. Xxxxxx Xxxxxx plc (“ZBH” or the “CompanyWTW”), defendants Xxxxx X. XxxxxxTowers Xxxxxx & Co. (“Towers”) (n/k/a WTW Delaware Holdings LLC), Xxxxxx X. XxxxxxGroup Holdings plc (“Willis”) (n/k/a Xxxxxx Xxxxxx Xxxxxx plc), Xxxxxx X. Xxxxxxxx Xx.and ValueAct Capital Management, Xxxx X. Xxxxxxx L.P. (collectively “ValueAct”) (collectively, the “Officer Corporate Defendants”), and defendants Xxxxxxxxxxx X. Xxxxxx, Xxxxx X. Xxxxxxx, Xxxx X. Xxxxxx, Xxxx X. XxxxxxxxxXxxxx (“Xxxxx”), Xxxxxxx X. XxxxxxxXxxxxxxxx (“Casserley”), and Xxxxxxx Xxxxx Xxxxxxxxx, Xxxxxx X. Xxxxxxxx, Xxxxxx X. Xxxxxxx, Xxxxxxx X. Xxxxxxxxx, Xxxxx X. Xxxxxxx, Ph.D., Xxxxxxx X. Xxxxxx (together with the Officer Defendantscollectively, the “Individual Defendants,” together with the Corporate Defendants, “Defendants,” and, together with ZBH and the Officer DefendantsLead Plaintiff, the “DefendantsParties,” and each a “Party”), by and through their counsel of record, and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”).1 Action.1 Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally finally, and forever compromise, settle, release, resolve, and dismiss with prejudice the Action and all Released Plaintiffs’ Claims (defined below). 1 All terms with initial capitalization not otherwise defined herein shall have the meanings ascribed to them in ¶ 1 herein. compromise, settle, release, resolve, and dismiss with prejudice the Action and all claims asserted therein against Defendants1.

STIPULATION AND AGREEMENT OF SETTLEMENT. This Stipulation stipulation and Agreement of Settlement, dated as of April 14, 2020 settlement agreement (the this “Stipulation”) ), dated April 29, 2005, is entered into between (a) Lead Plaintiffs Xxxxxx X. Xxxx by and among plaintiffs Xxxxx Xxxxx and Xxxx Xxxxxxxx Xxxxxxx, derivatively on behalf of Dynegy Inc. (“Lead Plaintiffs”), and additional plaintiffs UFCW Local 1500 and Xxxxxx Xxxxxxxx (together with Lead Plaintiffscollectively, “Plaintiffs”), on behalf of themselves and the Settlement Class (defined below); and (b) nominal defendant Xxxxxx Biomet Holdings, Dynegy Inc. (“ZBH” or the “Company”), defendants Xxxxx X. Xxxxxx, Xxxxxx X. Xxxxxx, Xxxxxx X. Xxxxxxxx Xx., Xxxx X. Xxxxxxx (collectively the “Officer DefendantsDynegy”), and defendants Xxxxxxxxxxx Xxxxxxx X. Xxxxxx, Xxxxxxx X. Xxxxxxxxx, Xxxxxx X. Xxxx, Xxxxx X. Xxxxxxx, Xxxx X. Xxxxxx, Xxxx X. Xxxxxxxxx, Xxxxxxx X. Xxxxxxx, Xxxxx XxxxxxxxxXxx X. Xxxxxxx, Xxxxxxx X. Xxxxxx, Xxxxxx X. Xxxxxxxx, Xxxxxx X. Xxxxxxxx, Xxxxx X. Xxxxxx, Xxxx X. Xxxxxx, X. Xxxx Xxxxx, X. Xxxx Xxxxxxx, Xxxxxx X. Xxxxxxxxxx, Xxxxxxx X. XxxxxxxxxXxxxxxxx, Xxxxxxxx X. Xxxxxx, and Xxxxx X. Xxxxxxx, Ph.D., Xxxxxxx X. Xxxxxx (together with the Officer Defendantscollectively, the “Individual Defendants,” and, together with ZBH and the Officer Defendants, ”). All parties to this Stipulation shall be collectively referred to as the “DefendantsParties.” The Parties have reached an agreement to settle the shareholder derivative litigation styled In re Dynegy Inc. Derivative Litigation, Lead Case No. 2002-25250, pending in the 164th District Court for Xxxxxx County, Texas (the “Derivative Litigation”), and embodies ) on the terms and conditions of the settlement of the above-captioned action (the “Action”).1 Subject set forth in this Stipulation, subject to the approval of the Court and the terms and conditions expressly provided herein, this approval. This Stipulation is intended by the Parties to fully, finally and forever 1 All terms with initial capitalization not otherwise defined herein shall have the meanings ascribed to them in ¶ 1 herein. compromise, settle, release, resolve, discharge and dismiss with prejudice the Action settle any and all claims asserted therein against Defendantsthat have been or could have been brought in the Derivative Litigation.