Stipulation and Agreement of Settlement Sample Contracts

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • May 15th, 2020 • New York

This stipulation and agreement of settlement (the “Stipulation”) is made and entered into through their respective undersigned counsel, by and between Lead Plaintiff the Public Employees’ Retirement System of Mississippi (“Lead Plaintiff” or “Mississippi PERS”), on behalf of itself and the Settlement Class (as defined below), and Dr. Reddy’s Laboratories Ltd. (“Dr. Reddy’s” or the “Company”), Dr. Reddy’s Laboratories, Inc.; Abhijit Mukherjee; G.V. Prasad; Saumen Chakraborty; and Satish Reddy (collectively, “Defendants,” and Lead Plaintiff and Defendants, collectively, the “Parties”). Subject to the terms and conditions set forth herein and the Court’s approval pursuant to Rule 23 of the Federal Rules of Civil Procedure, the settlement embodied in this Stipulation is intended by the Parties: (a) to be a full and final disposition of the above-captioned action (the “Action”) with respect to Defendants; and (b) to fully, finally and forever resolve, discharge, release, resolve, dismiss an

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STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • January 30th, 2022

This Stipulation and Agreement of Settlement (the “Stipulation”) is made and entered into by and between (a) the Greater Pennsylvania Carpenters’ Pension Fund and the Arkansas Teacher Retirement System (collectively, the “Institutional Investor Group” or “Lead Plaintiffs”), on behalf of themselves and all other members of the Settlement Class (as defined below), on the one hand, and (b) Celadon Group, Inc. (“Celadon” or “the Company”), Bobby L. Peavler (“Peavler”) and Paul A. Will (“Will”) (collectively, “Defendants”), on the other.1

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • December 22nd, 2020

This Stipulation and Agreement of Settlement (the “Stipulation”) is made and entered into by and between Firefighters’ Pension System of the City of Kansas City, Missouri Trust (“Lead Plaintiff”), on behalf of itself and all other members of the Settlement Class (defined below), on the one hand, and World Wrestling Entertainment, Inc. (“WWE” or the “Company”), Vincent K. McMahon, George A. Barrios, and Michelle D. Wilson (collectively, “Defendants”), on the other, and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”).

Contract
Stipulation and Agreement of Settlement • May 14th, 2021
STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • June 19th, 2015

This Settlement Agreement is entered into this 5th day of June, 2015 by and among the named plaintiffs: (I) Bill Anz; (2) Chris Armstrong; (3) Rodney Bender; (4) Debra Black; (5) Larry Black; (6) Josh Brewer; (7) Buckeye Management Group, LLC; (8) Kelvin Clark; (9) David Cooper; (10) Stephen Davis; (11) Gary Deyo; (12) Buster Diggs; (13) East Texas Poultry Supply; (14) Richard Engleman; (15) William Emestburg; (16) Rolland Garber; (17) Elvis

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • June 4th, 2021

This Stipulation and Agreement of Settlement (the “Stipulation” or “Settlement Agreement”) is made and entered into by and between Lead Plaintiffs Public Employees’ Retirement System of Mississippi (“MPERS”) and the Plumbers and Pipefitters National Pension Fund (“PPNPF,” and with MPERS, “Lead Plaintiffs”), and additional plaintiff Wisconsin Laborers’ Pension Fund (collectively with Lead Plaintiffs, “Plaintiffs” or “Class Representatives”), on behalf of themselves and all other members of the certified Class (defined below), on the one hand, and defendants JELD-WEN Holding, Inc. (“JELD-WEN” or the “Company”), and Mark A. Beck, L. Brooks Mallard, Kirk S. Hachigian, Gary S. Michel (collectively, the “Individual Defendants” and with JELD-WEN, the “Jeld-Wen Defendants”), and Onex Corporation (“Onex”) and its affiliated funds and entities, specifically Onex Partners Manager LP, Onex Partners III LP, Onex Partners III GP LP, Onex US Principals LP, Onex Partners III PV LP, Onex Partners III S

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • August 26th, 2019

This Stipulation and Agreement of Settlement (the “Stipulation”) is made and entered into by and between Lead Plaintiffs Granite Point Capital Master Fund, LP, Granite Point Capital Panacea Global Healthcare, Granite Point Capital Scorpion Focused Ideas Fund (collectively, “Granite Point”) and Simon James (collectively, “Lead Plaintiffs”), on behalf of themselves and all other members of the proposed Settlement Class (defined below), on the one hand, and Prothena Corporation plc (“Prothena” or the “Company”) and Dr. Gene Kinney (“Kinney”), Tran

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • January 3rd, 2022

This Stipulation and Agreement of Settlement is entered into by and between Ms. Lisa Hill-Green, individually as Plaintiff in Hill-Green v. Experian Information Solutions, Inc., Case No. 3:19-cv-00708 (E.D. Va.) (“the Action”), and as putative representative of the Rule 23(b)(2) Settlement Class,1 on the one hand, and Experian Information Solutions, Inc. (“Experian”), and each of its parents, predecessors, subsidiaries, affiliates, officers, directors, partners, employees, agents, servants, assignees, counsel, successors, and/or other transferees or representatives, on the other hand, subject to preliminary and final approval by the Court, by and through their respective counsel. Experian and Plaintiff, individually and as putative class representative, are referred to collectively herein as the “Parties.”

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • December 5th, 2022

This Stipulation and Agreement of Settlement (the “Stipulation” or “Settlement Agreement”) is made and entered into by and between (a) Court-appointed Class Representatives Oklahoma Firefighters Pension and Retirement System (“OFPRS”), Plymouth County Retirement Association (“PCRA”) and Electrical Workers Pension Fund, Local 103, I.B.E.W. (“Local 103”) (collectively, “Class Representatives”), on behalf of themselves and all other members of the Court-certified Class (defined below), on the one hand, and (b) Defendants Conduent Incorporated (“Conduent” or the “Company”), Ashok Vemuri, and Brian Webb-Walsh (the “Individual Defendants”, and together with Conduent the “Defendants” and, together with both Conduent and the Class Representatives, the “Parties”), on the other, by and through their counsel of record in the above-captioned litigation pending in the United States District Court for the District of New Jersey (the “Court”). This Stipulation is intended by the Parties to fully, fin

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • February 22nd, 2023 • California

This Stipulation and Agreement of Settlement is entered into by and between Plaintiff Angelica Cosio, individually and on behalf of all others similarly situated (“Cosio” or “Plaintiff”), on the one hand, and Defendants International Performing Arts Academy, LLC, Barbizon School of San Francisco, Inc., Lion Management Group, Inc., Larry D. Lionetti and Lena Quesada Lionetti (“Defendants,” and together with Plaintiff, the “Parties”), on the other hand, subject to preliminary and final approval by the Court, by and through their respective counsel.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Stipulation and Agreement of Settlement • April 21st, 2023 • New York
STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • October 24th, 2014

This Stipulation and Agreement of Settlement (the “Stipulation”) is made and entered effective October 24, 2014, by and among: (i) Lead Plaintiffs, the Massachusetts Pension Reserves Investment Management Board (“PRIM”) and State Boston Retirement Board (“SBRB”), as co-lead plaintiffs for the Common Stock Class (defined below), and Tennessee Consolidated Retirement System (“TCRS”), as lead plaintiff for the Preferred Stock Class (defined below) (collectively, the “Lead Plaintiffs”), for themselves and on behalf of all persons who are members of the Common Stock Class and/or Preferred Stock Class, respectively, (collectively, the “Plaintiffs”); (ii) Defendant Federal National Mortgage Association (“Fannie Mae” or the “Settling Defendant”); and (iii) the Federal Housing Finance Agency (“FHFA”) as Conservator for Fannie Mae (collectively, Lead Plaintiffs, Fannie Mae, and FHFA are referred to herein as the “Settling Parties”).

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • December 5th, 2020 • California

This Stipulation and Agreement of Settlement (the “Stipulation”) is entered into by and between Plaintiffs Edward Huyer, Connie Huyer, Carlos Castro and Hazel P. Navas-Castro (together, “Plaintiffs”), for themselves and the Class defined herein, on the one hand, and, on the other hand, Wells Fargo Bank, N.A. and Wells Fargo & Co. (collectively, “Wells Fargo”). Plaintiffs and Wells Fargo are referred to collectively in this Stipulation as the “Parties.”

IN RE: NATURAL GAS COMMODITY LITIGATION : : x Master File No. 03 CV 6186 (VM) THIS DOCUMENT RELATES TO: ALL ACTIONS : : Hon. Victor Marrero, USDJ
Stipulation and Agreement of Settlement • March 1st, 2006 • CMS Energy Corp • Electric & other services combined • New York

THIS STIPULATION AND AGREEMENT OF SETTLEMENT (the “Settlement Agreement”) is made and entered into on February 28, 2006, pursuant to Rule 23 of the Federal Rules of Civil Procedure. This Settlement Agreement is entered into on behalf of plaintiffs and the Class (as defined in Section l(c) hereof), by and through plaintiffs’ Lead Counsel (as defined in Section 1(j) hereof), and behalf of CMS Field Services (now known as Cantera Gas Company LLC) and CMS Marketing Services & Trading Company (now known as CMS Energy Resource Management Company) (both entities collectively, “CMS”), by and through its counsel of record in this action.

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • March 22nd, 2017 • California

This Stipulation and Agreement of Settlement (“Settlement Agreement” or “Settlement”) is entered into this th day of March, 2017 by and among the named Plaintiffs: Omar Vargas, Robert Bertone, Michelle Harris, Sharon Heberling, Kevin Klipfel, Andrea Klipfel, Maureen Cusick, Eric Dufour, Abigail Fisher, Christi Groshong, Virginia Otte, Tonya Patze, Lindsay Schmidt, Patricia Schwennker, and Patricia Soltesiz, Joshua Bruno, Jason Porterfield, and Jamie Porterfield (collectively, the “Named Plaintiffs” or “Class Representatives” or “Plaintiffs”) and Defendant, Ford Motor Company (“Ford”), by and through their respective counsel.

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • June 16th, 2021 • Pennsylvania

This Stipulation and Agreement of Settlement is entered into by and between Kimberly Deaton, both individually and on behalf of the Settlement Class (the “Class Representative”), and TransUnion LLC (“TransUnion”),1 subject to approval by the Court.

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • March 26th, 2017 • California

This Stipulation and Agreement of Settlement (“Settlement Agreement” or “Settlement”) is entered into this th day of March, 2017 by and among the named Plaintiffs: Omar Vargas, Robert Bertone, Michelle Harris, Sharon Heberling, Kevin Klipfel, Andrea Klipfel, Maureen Cusick, Eric Dufour, Abigail Fisher, Christi Groshong, Virginia Otte, Tonya Patze, Lindsay Schmidt, Patricia Schwennker, and Patricia Soltesiz, Joshua Bruno, Jason Porterfield, and Jamie Porterfield (collectively, the “Named Plaintiffs” or “Class Representatives” or “Plaintiffs”) and Defendant, Ford Motor Company (“Ford”), by and through their respective counsel.

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • August 22nd, 2003

This stipulation and agreement of settlement dated as of August 12th, 2003 is made and entered into by and between Lead Plaintiff, California State Teachers’ Retirement System (“CalSTRS” or “Lead Plaintiff”), on behalf of itself and the Class (as defined below), and defendant Homestore, Inc. (“Homestore”).

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • March 8th, 2021

This Stipulation and Agreement of Settlement dated July 10, 2020 (the “Stipulation”), is made and entered into by and among the following Parties (as defined below), each by and through their respective counsel: (i) plaintiffs to the above-captioned consolidated shareholder derivative action, Mohammed Fotouhi (“Fotouhi”), Fred Weiss (“Weiss”), David Plaza de la Fuente (“de la Fuente”), and Jesus Ladron Sanchez, (“Sanchez” and collectively, “Plaintiffs”), derivatively on behalf of Impinj, Inc. (“Impinj” or the “Company”); (ii) nominal defendant Impinj; and (iii) current and former officers and/or member of Impinj’s Board of Directors (the “Board”), defendants Chris Diorio, Eric Brodersen, Evan Fein, Gregory Sessler, Tom A. Alberg, Clinton Bybee, Peter Van Oppen, and Theresa Wise (the “Individual Defendants” and with Impinj, the “Defendants”). This Stipulation, subject to the approval of the United States District Court for the District of Delaware (the “Court”), is intended by the Parti

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • December 7th, 2005 • Kaiser Group Holdings Inc • Hazardous waste management • Delaware

This Stipulation and Agreement of Settlement (the “Agreement”) is submitted pursuant to Rules 7023 and 9019 of the Federal Rules of Bankruptcy Procedure. Subject to the approval of the Bankruptcy Court, this Agreement is entered into between and among the following parties: (i) James D. Pippin, on behalf of himself and the Class of ICT Spectrum Bankruptcy Claimants (1) (the “Class”), by and through his counsel, and (ii) Kaiser Group Holdings, Inc. (“Holdings”), and (iii) Kaiser Group International, Inc. (“Kaiser”) and its affiliated debtors(2) and debtors in possession (collectively with Kaiser, the “Debtors”).

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • April 23rd, 2021 • Arkansas

This Stipulation and Agreement of Settlement (“Agreement” or “Settlement”) is entered into between Plaintiff ARcare, Inc. (“Plaintiff” or “ARcare”), on behalf of itself and a class of similarly-situated persons (identified herein as the “Settlement Class”), on the one hand, and QIAGEN North American Holdings Inc. and QIAGEN LLC (formerly QIAGEN Inc.) (together, “Defendants”), on the other. The parties to this Agreement are collectively referred to as the “Parties.” This Agreement is intended by the Parties to fully, finally, and forever resolve, discharge, and settle the Released Claims (as the term is defined below), upon and subject to the terms and conditions hereof, and subject to the approval of the Court. This Agreement is entered into as of the date it is signed by the last of the Parties to sign it.

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STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • May 20th, 2011 • Fossil Inc • Watches, clocks, clockwork operated devices/parts

This Stipulation and Agreement of Settlement (“Stipulation”) dated May 4, 2011, is made and entered into by and among the following Parties: (i) City of Pontiac Policeman’s and Fireman’s Retirement System and Robert B. Minich (“Plaintiffs”), individually and derivatively on behalf of Fossil, Inc. (“Fossil” or the “Company”); (ii) Tom Kartsotis, Kosta N. Kartsotis, Michael W. Barnes, Jal S. Shroff, Alan J. Gold, Kenneth W. Anderson, Donald J. Stone, Michael Steinberg, Caden Wang, Richard H. Gundy, Mark D. Quick, Randy S. Kercho, Michael L. Kovar, Thomas R. Tunnell, Randy S. Hyne, Stephen Bock, and Junichi Hattori (the “Individual Defendants”); and (iii) Fossil, by and through its counsel of record in the Action. This Stipulation is intended by the Parties to fully, finally, and forever compromise, resolve, discharge, and settle the Released Claims and dismiss the Action with prejudice, upon the terms and subject to the conditions set forth herein.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA Alexandria Division
Stipulation and Agreement of Settlement • May 15th, 2013
STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • March 26th, 2018

This Stipulation and Agreement of Settlement is entered into by and between Olga Anderson, Kim Breeden, Brenda Walker and Carolyn Clark as putative representatives of the Settlement Class (collectively, “Class Representatives”),1 on the one hand, and Trans Union LLC, on the other hand, subject to preliminary and final approval by the Court, by and through their respective counsel.

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • February 18th, 2021 • New York

This Stipulation and Agreement of Settlement (the “Settlement Agreement”) is entered into, subject to Court approval, by and between (i) the Court-appointed lead plaintiff Teachers’ Retirement System of Louisiana (“Lead Plaintiff”) and additional Court-appointed class representatives Christine Fleckles, Julie Perusse and Alden Chace (collectively with Lead Plaintiff, “Plaintiffs” or “Class Representatives”) and (ii) defendants Pfizer Inc. (“Pfizer”), Henry A. McKinnell, Karen L. Katen, Joseph M. Feczko, and Gail Cawkwell (collectively, “Defendants” and, together with Plaintiffs, the “Parties”) in In re Pfizer Inc. Securities Litigation (the “Action”), pending in the United States District Court for the Southern District of New York (the “Court” or “District Court”), and embodies the terms and conditions of the settlement of the Action.1

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • February 28th, 2017 • Pennsylvania

This Stipulation and Agreement of Settlement, dated as of February 28, 2017 (the “Stipulation”) is entered into between (a) Arkansas Teacher Retirement System (“Arkansas Teachers”), Macomb County Employees Retirement System (“Macomb County”), and Laborers’ District Council and Contractors’ Pension Fund of Ohio (“Ohio Laborers”) (collectively, “Lead Plaintiffs”), on behalf of themselves and the Class (defined below); and (b) defendant DFC Global Corp. (“DFC Global” or the “Company”); defendants Jeffrey A. Weiss, Randy Underwood, William M. Athas, David Jessick, Kenneth Schwenke, Clive Kahn, John Gavin, Ronald McLaughlin, and Michael Kooper (collectively, the “Individual Defendants” and, together with DFC Global, the “DFC Global Defendants”); and defendants Credit Suisse Securities (USA) LLC and Nomura Securities International, Inc. (collectively, the “Underwriter Defendants” and, together with the DFC Global Defendants, the “Defendants”), and embodies the terms and conditions of the set

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • August 26th, 2016 • New York

This Stipulation and Agreement of Settlement (the “Settlement Agreement”) is entered into, subject to Court approval, by and between (i) the Court-appointed lead plaintiff Teachers’ Retirement System of Louisiana (“Lead Plaintiff”) and additional Court-appointed class representatives Christine Fleckles, Julie Perusse and Alden Chace (collectively with Lead Plaintiff, “Plaintiffs” or “Class Representatives”) and (ii) defendants Pfizer Inc. (“Pfizer”), Henry A. McKinnell, Karen L. Katen, Joseph M. Feczko, and Gail Cawkwell (collectively, “Defendants” and, together with Plaintiffs, the “Parties”) in In re Pfizer Inc. Securities Litigation (the “Action”), pending in the United States District Court for the Southern District of New York (the “Court” or “District Court”), and embodies the terms and conditions of the settlement of the Action.1

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • March 5th, 2020 • Missouri

This Stipulation and Agreement of Settlement, dated as of March 5, 2020 (the “Stipulation”) is entered into between (a) Lead Plaintiff Louisiana Sheriffs’ Pension & Relief Fund (“Lead Plaintiff”), on behalf of itself and the Settlement Class (defined below); and (b) defendant Centene Corporation (“Centene” or the “Company”) and defendants Michael F. Neidorff and Jeffrey A. Schwaneke (the “Individual Defendants” and, with Centene, “Defendants”), by and through their counsel of record, 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 compromise, settle, release, resolve, discharge and dismiss with prejudice the Action and all Released Plaintiffs’ Claims (defined below).

AMENDMENT TO STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • January 24th, 2020

This Amendment (“Amendment”) to the Stipulation and Agreement of Settlement (“Settlement Agreement”) is entered into by and among the named Plaintiffs Omar Vargas, Robert Bertone, Michelle Harris, Sharon Heberling, Kevin Klipfel, Andrea Klipfel, Maureen Cusick, Eric Dufour, Abigail Fisher, Christi Groshong, Virginia Otte, Tonya Patze, Lindsay Schmidt, Patricia Schwennker, and Patricia Soltesiz, Joshua Bruno, Jason Porterfield, and Jamie Porterfield (collectively, the “Named Plaintiffs” or “Class Representatives” or “Plaintiffs”), Defendant Ford Motor Company (“Ford”) (collectively, the “Settling Parties”), and Objectors Brenda Lott, Suzanne Lutz, Carlie Olivant, Gail Slomine, Philip Woloszyn (collectively, the “Lott Objectors”). and James “Jason” DeBolt (“Objector DeBolt”, and collectively with the Lott Objectors, the “Objectors”), by and through their respective counsel.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
Stipulation and Agreement of Settlement • June 18th, 2021 • New York
Stipulation and Agreement of Settlement
Stipulation and Agreement of Settlement • March 3rd, 2017 • Geron Corp • Pharmaceutical preparations • California
STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • March 7th, 2024

This Stipulation and Agreement of Settlement (the “Stipulation”) is made and entered into by and between the Court-appointed Lead Plaintiff Alan Narzissenfeld, (“Lead Plaintiff”), on behalf of himself and all other members of the Settlement Class (defined below), on the one hand, and individual Defendants Jonathan Webb (“Webb”), David Lee (“Lee”), and Loren Eggleton (“Eggleton” and collectively with Webb and Lee, the “Individual Defendants”) (Lead Plaintiff and the Individual Defendants collectively, the “Parties”), on the other, and embodies the terms and conditions of the settlement of the above-captioned action (the “Action”).

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA VALDOSTA DIVISION‌
Stipulation and Agreement of Settlement • October 31st, 2019

This Stipulation and Agreement of Settlement (the “Stipulation”), dated October 28, 2019, is made and entered into by and among the following Settling Parties (as defined herein)1, each by and through their respective counsel: (1) plaintiffs to the Federal Derivative Action (William D. Wrigley (“Wrigley”) and Stephen Goldberger (“Goldberger”)); (2) plaintiffs in the State Derivative Action (the Margaret Cicchini Family Trust (the “Trust”) and Frank Garnier (“Garnier”)); (3) the Shareholder Janet Lovette; (4) the Individual Defendants (George E. Deese, Allen L. Shiver, R. Steven Kinsey, Karyl H. Lauder, Bradley K. Alexander, Rhonda O. Gass, Benjamin H. Griswold, IV, Richard A. Lan, Margaret G. Lewis, Amos R. McMullian, Joseph Vincent Shields, Jr., David V. Singer, James T. Spear, Melvin T. Stith, and C. Martin Wood, III); and (5) nominal defendant Flowers Foods, Inc.

STIPULATION AND AGREEMENT OF SETTLEMENT
Stipulation and Agreement of Settlement • November 12th, 2014 • California

This Settlement Agreement is made between plaintiffs Payam Ahdoot (“Ahdoot”) and Brandon Clark (“Clark”) (collectively “Plaintiffs”) for themselves and on behalf of the Settlement Class (defined below), on the one hand, and Defendant Babolat VS North America, Inc., on the other hand, to settle Ahdoot v. Babolat VS North America, Inc., CV13-02823 GAF

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