WITHOUT PREJUDICE SAVE AS TO COSTS
28 September 2026
Dear Counsel,
Proposed settlement of Matter LT-884
Our client offers to resolve all claims and counterclaims in the above matter on the following terms.
Settlement payment: $18,500,000
Payment timing: Five business days after execution
Release: Mutual release of all known and unknown claims
Confidentiality: Standard mutual confidentiality
Offer expiry: 17:00 on 30 September 2026
This offer is capable of acceptance by countersigned copy. We look forward to your response.
Rowan & Finch LLP