The Settlement Class

Includes all beneficiaries of structured settlement annuities assigned to Athene London Assignment Corporation (formerly known as Aviva London Assignment Corporation and as CGNU London Annuity Service Corp.), which includes all annuities covered by the Capital Maintenance Agreement between CGU International Insurance plc and CGNU London Annuity Service Corp. dated February 1, 2002, where such annuities remained in force as of October 2, 2013.

Excluded from the proposed class are the officers and directors of any Defendant and members of their immediate families and any entity in which any Defendant has a controlling interest, the legal representatives, heirs, successors or assigns of any such excluded party, the judicial officer(s) to whom this action is assigned, and the members of their immediate families.

Terms of Settlement

• Requires Athene Defendants to create a new Capital Maintenance Agreement which replicates, and then improves upon, the terms of the CMA whose purported cancellation is at issue in this case. This new CMA will be backed by Athene Holding Ltd., the ultimate, publicly traded, corporate parent of all other Athene Defendants. Plaintiffs' expert has opined that the entity that will issue the new CMA is better capitalized than CGU .

• It provides cash relief in amounts totaling at least $7.3 million.
• It requires Defendants to pay the costs of notice and settlement administration up to a total of $200,000 (up to $100,000 for each of the Athene and Aviva
  Defendants), as well as up to an additional $12,500 from each Defendant group for a service award, if approved by the
  Court, to be paid to the named Plaintiff, John Griffiths.
• It provides for an additional payment by Aviva of 25% of any amount it obtains in resolution of any claim it files against the Athene Defendants for indemnification in connection with the acts at issue in the Amended Complaint.