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Ehi;Elffi INDIVIDUAL RELEASE OF CLAIMS
<br />Erfi
<br />GBD DV3GsYBTMD In re Mercedes-Benz Emissions Litigation
<br />Case No. I 6-cv-88 I (D.N.J.)
<br />MUST BE COMPLETED BY C.LASS MEMBER
<br />PRIORJO RECEIVING ANY CLASS MEMBER PAYMENT
<br />In exchange for the Class Member Payment! that Daimler AG and Mercedes-Benz USA,
<br />LLC (the'oMercedes Defendants") and Robert Bosch GmbH and Robert Bosch LLC (the
<br />"Bosch Defendants") have agreed to provide to me, should the Settlement Administrator
<br />determine I am eligible to receive the Class Member Payment under the class action
<br />settlement agreements in this case2 ithe "Class Action Agreements"), the sufficiency of
<br />which I hereby acknowledge, I, on behalf of myself and my agents, heirs, executors and
<br />administrators, successors, assigns, insurers, attorneys (including any of my attorneys
<br />who are not Class Counsel), representatives, shareholders, owners associations, and any
<br />other legal or natural persons who may claim by, through, or under them, hereby fully,
<br />finally, irrevocably, and forever release, waive, discharge, relinquish, settle, and acquit
<br />any and all claims, demands, actions, or causes of action, of any kind or nature
<br />whatsoever, whether in law or in equity, contractual, quasi-contractual or statutory,
<br />known or unknown, direct, indirect or consequential, liquidated or unliquidated, past,
<br />present or future, foreseen or unforeseen, developed or undeveloped, contingent or non-
<br />contingent, suspected or unsuspected, whether or not concealed or hidden, that I may
<br />have, purport to have, or may hereafter have against any Released Party arising out of, in
<br />whole or in part, or in any way related to the BlueTEC Diesel Matter, except for claims
<br />of personal injury or wrongful death (the "Released Claims," as defined more fully in
<br />Section 10.3 of the Class Action Agreements).
<br />"BlueTEC Diesel Matter" means allclaims arising from or in any rvay relating to: (l) the
<br />design, manufacture, assembly, testing, development, installation, performance, presence,
<br />disclosure, or nondisclosure of any auxiliary emission control device ("AECD") (as
<br />defined in 40 C.F.R. $ 86.1803-01) ordefeat device (as defined in 40 C.F.R. $ 86.1803-01
<br />or 42 U.S.C. $ 7522(a)(3XB)) in any Subject Vehicle, as that term is defined in the Class
<br />Action Agreements; {2) the design, manufacture, assembly, testing, development,
<br />installation, or performance of emission control equipment and methods and related
<br />hardware or software in Subject Vehicles, including Diesel Exhaust Fluid and associated
<br />equipment, Selective Catalytic Reduction systems, electronic control units, and emission-
<br />related software programming, coding, and calibrations; (3) overpayment or diminution in
<br />value related to the design, manufacture, assembly, testing, development, installation, or
<br />I rhe terms "Action," "Class Counsel,n' "class Member Payment," o'court," "Final Approval
<br />Order,"'oRelease," "Released Claims," and "settlement Administrator," "Valid Claim," and any
<br />other term not specifically defined herein, have the meanings given to them in the Class Action
<br />Agreements. A copy of each Class Action Agreement is available at mbbluetecsettlement.com.
<br />2 D.E. 299-2, Ex. A (settlement with Mercedes Defendants); D.E. 306-2, Ex. A (settlement r,vith
<br />Bosch Defendants).
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