UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
STIPULATION AND AGREEMENT OF SETTLEMENT
This Stipulation and Agreement of Settlement (the “Stipulation”) is submitted pursuant to Rules 23.1 of the Federal Rules
of Civil Procedure. Subject to the approval of the Court, this Stipulation is entered into among Plaintiffs Michael Blizman,
Nathan Hostacky, Michael Morris, and Phung Vu, derivatively on behalf of nominal defendant, Microtune, Inc. and on behalf of
the Microtune Shareholders, Nominal Defendant Microtune, Inc. (“Microtune” or the “Company”) and Individual Defendants
James A. Fontaine, James H. Clardy, William P. Tai, Harvey B. Cash, Walter S. Ciciora, Steven Craddock, Anthony J. LeVecchio
(collectively, the “Director Defendants”), Douglas J. Bartek (“Bartek”), William Housley (“Housley”), Everett Rogers
(“Rogers”), and Nancy A. Richardson (“Richardson”), by and through their respective counsel.
IN THE MATTER OF MICROTUNE, INC. § Master File No. 4:03-cv-409
§ (Judge Brown)
A. On and after October 30, 2003, the following derivative suits were filed in the U.S. District Court for the Eastern District
of Texas against Microtune, as a nominal defendant, and certain of its present or former officers and directors: Morris v.
Fontaine, et al. , 4:03-cv-0409; Hostacky v. Fontaine, et al. , 4:03-cv-0411; Vu v. Bartek, et al. , 4:03-cv-0471; and Blizman v.
Bartek, et al. , 4:03-cv-0472.
B. By Orders dated December 29, 2003 and January 20, 2004, (the “Consolidation Orders”), the Court consolidated the four
separately filed derivative actions listed above in paragraph A for all purposes into Morris v. Fontaine, et al., 4:03-cv-0409 (the
derivative suits hereafter referred to as the “Action”) and deemed the complaint in Morris v. Fontaine, et al . the operative
complaint for the Action (“Derivative Complain