UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISIONStipulation and Agreement • September 6th, 2022 • Geron Corp • Pharmaceutical preparations • California
This Stipulation and Agreement of Settlement, dated as of September 2, 2022 (the “Stipulation”), is entered into between (a) Julia Junge and Richard Junge (“Lead Plaintiffs” or “Class Representatives”), on behalf of themselves and the plaintiff class certified by the Court (the “Class,” as defined in ¶1(h) below); and (b) defendants Geron Corporation (“Geron”) and Dr. John A. Scarlett (“Dr. Scarlett,” and together with Geron, “Defendants”), and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”). Subject to the approval of the Court and the terms and conditions expressly provided herein, this Stipulation is intended to fully, finally and forever compromise, settle, release, resolve, and dismiss with prejudice the Action and all Released Plaintiffs’ Claims (as defined below in ¶1(qq) against Defendants’ Released Parties (as defined below in ¶1(r).
