statements, representations, misrepresentations, omissions, allegations, disclosures, facts, practices, events, claims, or any other matters, things, or causes whatsoever, or any series thereof,
that: (a) were alleged, asserted, set forth, claimed, embraced, involved, or referred to in, or related to, in each case, the Action, or (b) which could have been asserted against any of Plaintiffs Releasees regarding (i) the
compensation paid to the directors of the Company in Fiscal Year (FY) 2019, FY 2020, and FY 2021; (ii) the approval or receipt of compensation to the directors of the Company in FY 2019, FY 2020, or FY 2021; (iii) any disclosures made or
not made with respect to the foregoing; and (iv) any operative facts, allegations, claims, or prayer for relief made in the Action, except for claims relating to the enforcement of the Settlement.
Stipulation §1(c): Defendants Releasees means each of Defendants and each of their and Stokes respective
parents, subsidiaries, affiliates and controlling persons, and any current or former officer or director of any of the foregoing, and each of their respective past, present, or future family members, spouses, heirs, trusts, trustees, executors,
estates, administrators, beneficiaries, distributes, foundations, agents, employees, fiduciaries, partners, partnerships, general or limited partners or partnerships, joint ventures, member firms, limited liability companies, corporations,
divisions, affiliates, associated entities, stockholders, principals, officers, directors, managing directors, members, managing members, managing agents, predecessors,
predecessors-in-interest, successors, successors-in-interest, assigns, financial or
investment advisors, advisors, consultants, investment bankers, entities providing any fairness opinion, underwriters, brokers, dealers, lenders, commercial bankers, attorneys (including all Defendants counsel in this action), counsel,
personal or legal representatives, accountants, insurers, co-insurers, reinsurers, and associates.
Stipulation §1(e): Plaintiffs Released Claims means and includes any and all manner of claims, debts, demands,
rights, liabilities, losses, obligations, duties, damages, costs, debts, expenses, interest, penalties, sanctions, fees, attorneys fees actions, potential actions, causes of action, suits, agreements, judgments, decrees, matters, issues and
controversies of any kind, nature, or description whatsoever, whether known or unknown, disclosed or undisclosed, accrued or unaccrued, apparent or not apparent, foreseen or unforeseen, matured or not matured, suspected or unsuspected, liquidated or
not liquidated, fixed or contingent, including Unknown Claims (as defined herein), whether based on state, local, foreign, federal, statutory, regulatory,
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