Plaintiffs and Defendant, Associated Bank, N.A., through their respective undersigned counsel, notified the Court in the MDL actions pending in southern Florida that as of November 23, 2011, they have reached an agreement in principle, under which Associated Bank, N.A. will pay the sum of Thirteen Million Dollars ($13,000,000.00) in exchange for a full and complete release of all claims that were or could have been brought against Associated Bank, N.A. in this multidistrict litigation. The proposed settlement will be memorialized in a complete written settlement agreement and related documents, which the parties will endeavor to file with the Court as part of a motion for preliminary approval within approximately 45 days.
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