CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE

- 1 - CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE This CLASS ACTION SETTLEMENT AGREEMENT AND RELEASE ( AGREEMENT ), made on March 17, 2021 ( Execution Date ), subject to final approval by the Circuit Court of Jefferson County, Missouri ( Court ), is between (a) Alberta Haskins and David Duncan ( CLASS Representatives ), individually and as the representatives of the Classes, and (b) ally Bank and ally Financial Inc. The CLASS Representatives, ally Bank, ally Financial Inc., and the Classes are sometimes individually called a Party and collectively called the Parties. Other capitalized terms are defined in Paragraph 2 or elsewhere in this AGREEMENT . WHEREAS, the CLASS Representatives are the named defendants and counterclaimants in the civil ACTION pending before the Court, styled ally Financial Inc.

Ally Financial Inc. v. Alberta Haskins and David Duncan, Case No. 16JE-AC01713-01 (together with any and all actions that may be consolidated, the “Litigation”); and . WHEREAS, the Class Representatives are asserting claims and seeking relief against Ally for alleged violations of the Uniform Commercial Code as enacted in the various states, as

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  Agreement, Class, Release, Action, Settlement, Ally, Class action settlement agreement and release

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