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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.

Shook, Hardy & Bacon L.L.P., 2555 Grand Blvd., Kansas City, Missouri 64108. 2.3 Business Day. “Business Day” means any day other than a Saturday, a Sunday, or a day on which banks in New York, New York, Charlotte, North Carolina, or St. Louis, Missouri are authorized or obligated by law or executive order to be closed. 2.4 . Cash Fund.

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