In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 4583

JUDICIAL CONSENT ORDER AS TO GETTY PETROLEUM MARKETING, INC.; LUKOIL AMERICAS CORPORATION individually and as f/k/a, d/b/a and/or successor in liability to Getty Petroleum Marketing Inc., Lukoil North America LLC and/or Lukoil OilCompany; LUKOIL NORTH AMERICA LLC, individually and as f/k/a, d/b/a and/or successor in liability to Getty Petroleum Marketing, Inc., Lukoil Americas Corporation and/or OAO Lukoil; LUKOIL OIL COMPANY, a/k/a OAO Lukoil a/k/a Public Joint Stock Company Oil Company LUKOIL a/k/a/PJSC Oil Company Lukoil, individually and as f/k/a, d/b/a and/or successor in liability to GettyPetroleum Marketing Inc., Lukoil Americas Corporation and/or Lukoil North America LLC; LUKOIL PAN AMERICAS, LLC ONLY:THEREFORE, with the consent of the Parties to this JCO,it is hereby ORDERED and ADJUDGED: Within fourteen (14) Days after the effective date of this JCO, GPMI and/or the Lukoil Defendants shall pay, or cause to be paid on their behalf, the Plaintiffs Twenty Two Million Dollars ($22,000,000.00) in full and complete satisfaction of Plaintiffs' claims that are released or for which a covenant not to sue is provided in Section VI of the JCO. Nothing contained in this JCO shall be considered an admission by the Settling Defendants, or a finding by the Plaintiffs or this Court, of any wrongdoing or liability on the Settling Defendants' part. Within thirty days of the Plaintiffs' receipt of payment as set forth in Section V above, Plaintiffs shall request that the Court dismiss this Complaint as to GPMI and the Lukoil Defendants with prejudice pursuant to Fed. R. Civ. P. 41 (a) (2). The Parties to this JCO agree that it was negotiated fairly between them at arms' length and that the final terms of this JCO shall be deemed to have been jointly and equally drafted by them, and that the provisions of this JCO therefore should not be construed against a Party to it on the grounds that the Party drafted or was more responsible for drafting the provision(s) and further set forth in this Order. SO ORDERED. (Signed by Judge Vernon S. Broderick on 3/27/2020) (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit, # 29 Exhibit, # 30 Exhibit, # 31 Exhibit, # 32 Exhibit)Filed In Associated Cases: 1:00-cv-01898-VSB, 1:08-cv-00312-VSB-DCF (rro)

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Case 1:08-cv-00312-VSB-DCF Document 593 Filed 02/27/20 Page 26 of 30 One Bryant Park New York, NY 10036 For LAC and LNA: Robert Ferluga Lukoil Americas Corporation 505 Fifth Avenue, 9th Floor New York, NY 11554 For LPA: Managing Director Lukoil Pan Americas, LLC 1095 Avenue of the Americas New York, NY 10036 41. The Parties to this JCO agree that it was negotiated fairly between them at arms' length and that the final terms of this JCO shall be deemed to have been jointly and equally drafted by them, and that the provisions construed against a of Party to this JCO therefore it on the grounds should that not the Party drafted or was more responsible for drafting the provision(s). SO ORDERED this 27th day of March, 2020 U.S.D.J. Gurbir S. Grewal Attorney General of New Jersey Attorney for Plaintiffs By: 26 be Case 1:08-cv-00312-VSB-DCF Document 593 Filed 02/27/20 Page 27 of 30 Gurbir S. Grewal, Attorney General of New Jersey Attorney for Plaintiffs . (/71 /j7 / :fa'1 A ,A J ./ 1 tz:,t~t::Zt,. ,.)~C ~,,,,'::J.,L_.f!..<~·--·--------··'"'-Gwery· F y Deputy Attorney General By: Dated: ' ~I /9-r:, . ;/ l V Case 1:08-cv-00312-VSB-DCF Document 593 Filed 02/27/20 Page 28 of 30 Gwen Farley Deputy Attorney General Dated: NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION AND NEW JERSEY SPILL COMPENSATION FUND CONSENT TO THE FORM AND ENTRY OF THIS ORDER McCabe, Commissioner New Jersey Department of Environmental Protection, and Administrator New J~rsey Spill Compensation Fund Dated: 27 Case 1:08-cv-00312-VSB-DCF Document 593 Filed 02/27/20 Page 29 of 30 TO THE FORM AN ENTRY OF 1 GAO UJKCIL CON iJEN'r ::; LUJ<O LL PAN AMERICAS I ,JC JOJNT :;;''('OCK C(JMPl\NY OU, COMPANY UJKOIL AND ENTRY OF THI ORDER L,LC CONS8NTS TO THE FORM AND ENTRY OF' 'l:H'.rn ORDER By; r:; imon FcmnE: r Ma nag Director Dateld: 28 Case 1:08-cv-00312-VSB-DCF Document 593 Filed 02/27/20 Page 30 of 30 LUKOIL AMERICAS CORPORATION CONSENTS TO THE FORM AND ENTRY OF 1.'HIS ORDER By: Robert €~..F.1 ug?....... CEO Dated: LUKOIL NORTH AMERICA, LLC CONSENTS TO THE FORM AND .ENTRY OF THIS ORDER By: Robert Ferluga CEO Dated: OAO LUKOIL N/K/A PUBLIC JOINT STOCK·COMPANY OIL COMPANY LUKOIL CONSENTS. TO THE E"ORM AND ENTRY OE' THIS ORDER By: - ......................- -..---····..···········---··-····---~ Anatoly Martynov Dated: ---·----· · - - - LUKOIL PAN AMERICA., LLC CONSENTS TO THE E'ORM AND ENTRY OF THIS ORDER By: Simon F'enner Managing Dated: 28

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