SETTLEMENT AGREEMENT AND RELEASE - …

1 of 59 SETTLEMENT AGREEMENT AND RELEASE This SETTLEMENT AGREEMENT and RELEASE (hereinafter, AGREEMENT , as defined below) is entered into by and between (1) Kent Eubank, Jerry Davis, Ricky Falaschetti, Rita Cicinelli, Robert Josephberg, Jeffrey Acton, Kenneth Hechtman, James Neiman, Amy Chasin and Edward Ruhnke, (the Named Plaintiffs ), for themselves and on behalf of the SETTLEMENT Class (as defined below) and all members of the SETTLEMENT Class (collectively Plaintiffs , as defined below), and (2) Defendants Pella Corporation and Pella Windows and Doors, Inc. (collectively Defendants ), for the purpose of settling and finally and completely resolving certain claims and lawsuits, as set forth herein, which the Named Plaintiffs, the SETTLEMENT Class, or any SETTLEMENT Class Member (as defined below) currently have against Defendants or any of the Releasees (as defined below), as well as any and all future or potential claims, whether known or unknown, which the Named Plaintiffs, the SETTLEMENT Class, and any SETTLEMENT Class Member could have or may have against Defendants or any of the Releasees arising out of or in any way relating to the design, manufacture, sale, distribution, marketing, warranty, service, use, performa

1 of 59 SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release (hereinafter, “Agreement”, as defined below) is entered into by and between (1) Kent Eubank, Jerry Davis, Ricky Falaschetti, Rita Cicinelli,

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