THE CIRCUIT COURT OF BERKELEY COUNTY, WEST VIRGINIA
WILLIAM SHINGLETON, et al.
on behalf of themselves and all
others similarly situated,
Civil Action No. 98-C-517
ICT GROUP, INC., a Pennsylvania
Corporation, et al.,
) PROPOSED SETTLEMENT AGREEMENT
This Proposed Settlement Agreement (hereinafter “Agreement”) will be submitted to the Court for its consideration and
approval as required by Rule 23(e) of the West Virginia Rules of Civil Procedure. The “Parties” to this Agreement are as follows:
William Shingleton, Melissa Blair, Denice Gribble, 1 Jenni Gibson, on behalf of themselves and all others similarly situated
(collectively hereinafter the “Class”); ICT Group, Inc., a Pennsylvania corporation, AND individually and in their corporate
capacity: John Brennan, Anne Beeson, Vincent Paccapaniccia, Vincent Dadamo, Timothy Kowalski, Stephanie Koenig, Jack
Magee, John Campbell, Carl Smith, Dean Kilpatrick, Charles Feitner, and Tony Ditlow (collectively hereinafter “Defendants” or,
as appropriate, “ICT” or “Individual Defendants”).
This action was filed in October 1998, by former ICT employee William Shingleton on behalf of a class of employees at a
single ICT facility in Martinsburg, West Virginia. Shingleton’s complaint alleged that ICT deprived him and other Martinsburg
employees of the wages to which they were entitled by failing to pay them for all of the hours they worked.
On July 29, 1999, the Court certified part of the case as a class action on behalf of employees at ICT’s Martinsburg facility.
On April 30, 2001, Plaintiffs moved to file a “Second” (actually third) Amended Complaint (hereinafter “Complaint”). The Court
granted the motion, and Plaintiffs filed their Complaint which, among other things, expanded the Class to include all employees
from all of ICT’s W