Declaration of K. Rehns in Support of Plaintiffs' Motion for - Lehman ...

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Case 1:09-md-02017-LAK Document 666-1 Filed 01/13/12 Page 13 of 74 agency, arbitration forum or other tribunal, except as necessary to enforce the terms of this Order and/or the Settlement, including, but not limited to, the Judgment and the release of the Settled Claims provided for in the Stipulation and the Judgment 26. Unless otherwise provided in the Stipulation, there shall be no distribution of any of the Net Settlement Fund to any Class Member until a plan of allocation is finally approved and is affirmed on appeal or certiorari or is no longer subject to review by appeal or certiorari and the time for any petition for rehearing, appeal or review, whether by certiorari or otherwise, has expired. 27. Upon the date for publishing the Summary Notice, pending final determination of whether Settlement should be approved, the Lead Plaintiffs, all putative Class Members, and each of them, and anyone who acts or purports to act on their behalf, shall not institute or commence any action which asserts the Settled Claims against the Released Parties, unless such putative Class Member requests exclusion from the Settlement Class in accordance with the Notice. 28. In the event that the Settlement fails to become effective in accordance with its terms, or if the Judgment is not entered or is reversed, vacated or materially modified on appeal (and, in the event of material modification, if any party elects to terminate the Settlement), this Order (except Paragraphs 25 and 28) shall be null and void, the Stipulation shall be deemed terminated, and the parties shall return to their positions without prejudice in any way, as provided for in the Stipulation. IT IS SO ORDERED. DATED: THE HONORABLE LEWIS A. KAPLAN UNITED STATES DISTRICT COURT JUDGE
Case 1:09-md-02017-LAK Document 666-1 Filed 01/13/12 Page 14 of 74 EXHIBIT A-1
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Declaration of K. Rehns in Support of Plaintiffs' Motion for - Lehman ...

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