Common Contracts

STIPULATION AND AGREEMENT OF COMPROMISE, SETTLEMENT, AND RELEASE

Stipulation and Agreement of Compromise, Settlement, and Release • May 8th, 2020 • Delaware

• Contract Type
  Stipulation and Agreement of Compromise, Settlement, and Release
• Filed
  May 8th, 2020
• Jurisdiction
  Delaware

This Stipulation and Agreement of Compromise, Settlement, and Release (this “Stipulation”), dated May 8, 2020, is entered into by and between (i) lead plaintiff Mark Jacobs (“Plaintiff” or “Jacobs”), on his own behalf and on behalf of the Class,1 (ii) defendant D. Ronald Yagoda (“Yagoda” and, together with defendant Phillip O. Elbert (“Elbert”), the “Special Committee”), (iii) defendants James Rustin Roach (“Roach”) and Michael R. Hill (“Hill,” and, together with Roach, the “Management Directors”), and (iv) defendants Philip A. Falcone (“Falcone”), Keith M. Hladek (“Hladek”), Paul Voigt (“Voigt”), and HC2 Holdings, Inc. (“HC2”) (collectively, the “HC2 Defendants,” and along with the Special Committee and Management Directors, the “Defendants,” and together with Plaintiff, the “Parties”), in the action captioned Schuff International, Inc. Stockholders Litigation, Consol. C.A. No. 10323-VCZ (the “Action”), all by and through their respective undersigned counsel.‌