CLASS ACTION SETTLEMENT AGREEMENTClass Action Settlement Agreement • February 25th, 2021
Contract Type FiledFebruary 25th, 2021This Settlement Agreement, dated March 27, 2019 (the “Stipulation”), is made and entered into by and among the following Settling Parties (as defined further in Section III hereof) to the above-entitled Litigation: (i) Lead Plaintiffs Sheet Metal Workers Local 32 Pension Fund and Ironworkers St. Louis District Council Pension Fund and additional plaintiff Sheet Metal Workers Local #218(S) Pension Fund (“Plaintiffs”) (on behalf of themselves and each of the Settlement Class Members), by and through their counsel of record in the Litigation; and (ii) Defendants Terex Corporation (“Terex” or the “Company”), Thomas J. Riordan and the Dismissed Defendants, by and through their counsel of record in the Litigation. 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.