STIPULATION AND AGREEMENT OF SETTLEMENTFebruary 4th, 2019
FiledFebruary 4th, 2019This Stipulation and Agreement of Settlement (the “Producer Class Action Settlement Agreement”) is made pursuant to Rule 23 of the Federal Rules of Civil Procedure in the above- titled litigation (the “Producer Class Action”). Subject to the approval of this Court, this Producer Class Action Settlement Agreement is entered into among Plaintiffs John Fastrich, Universal Investment Services, Inc., and Reginald J. Good (collectively, “Representative Plaintiffs”), on behalf of themselves and each of the Class Members (as defined below), and Defendants Continental General Insurance Company (“CGI”), Great American Financial Resources, Inc. (“GAFRI”), American Financial Group, Inc. (“AFG”), Loyal American Life Insurance Company (“LALIC”) and American Retirement Life Insurance Company (“ARLIC”). The Representative Plaintiffs and Defendants are referred to here as the “Settling Parties” or “Parties” and each individually as a “Party.” The Parties intend this Producer Class Action Settlement Agr