1. Consideration and Monetary Conditions. (a) Plaintiff shall file no later than 5:00 p.m. CDT on July 5, 2022, the stipulation of dismissal with prejudice of all of Plaintiff’s claims against Defendants (“Plaintiff’s Stipulation of Dismissal”), attached hereto as Exhibit A.
(b) Defendants shall file no later than 5:00 p.m. CDT on July 5, 2022, the stipulation of dismissal with prejudice of all of Defendants’ claims against Plaintiff (“Defendants’ Stipulation of Dismissal”), attached hereto as Exhibit B.
(c) Within 5 business days after the Court enters Plaintiff’s Stipulation of Dismissal and Defendants’ Stipulation of Dismissal, Defendants shall pay Plaintiff the sum of Twenty Million Dollars ($20,000,000) (the “Settlement Amount”).
(d) The Settlement Amount set forth in Paragraph 1(c) shall be paid by wire transfer of immediately available funds to an account designated in writing by Insignia.
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