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COMPROMISE AND SETTLEMENT AGREEMENTCompromise and Settlement Agreement • October 8th, 2009 • California
This Compromise and Settlement Agreement (the “Settlement Agreement” or “Settlement”), dated as of October 8, 2009, is entered into by and between Debora K. Biggers, Carl Goodman, Anna Scarpa, and Marjorie Norris (collectively the “Plaintiff Class Representatives”), on behalf of themselves and on behalf of the individuals named on Exhibit A hereto (the Class Representatives and the persons listed on Exhibit A hereto are collectively referred to as the “Plaintiff Class Members”), on the one hand, and Heller Ehrman LLP (the “Debtor”), Heller Ehrman (California), A Professional Corporation; Heller Ehrman (Washington), P.S.; Heller, Ehrman, White, & McAuliffe (Oregon), P.C.; Heller Ehrman (Alaska), P.C.; Heller Ehrman (New York), A Professional Corporation; Heller Ehrman (China), P.C., (collectively, the “Professional Corporation Defendants”); individuals Matthew Larrabee, Robert Hubbell, Steven Koppel, Marie Fiala, Mark Weeks, Barry Levin, Kenneth Chernof, Lawrence Keeshan, Robert Rosenfe
