Stipulation

Date: 
Monday, May 3, 2004
Document Type: 
Stipulations - Miscellaneous
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA



UNITED STATES OF AMERICA,    
Department of Justice, Antitrust Division
1401 H Street, NW
Suite 4000
Washington, DC 20530

                  Plaintiff,

                  v.

MANULIFE FINANCIAL CORPORATION   
200 Bloor St. East
Toronto, Ontario M4W 1E5, Canada

                  Defendant.


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Civil Action No.

Filed:

STIPULATION

It is stipulated by and between the undersigned parties, by their respective attorneys, that:

1. The parties consent that the Court may file and enter a Final Judgment in the form attached to this Stipulation, on the Court's own motion or on the motion of any party at any time, and without further notice to any party or other proceedings, if Plaintiff has not withdrawn its consent, which it may do at any time before the entry of judgment by serving notice of its withdrawal on defendant Manulife Financial Corporation, and filing that notice with the Court;

2. Defendant Manulife waives any objection to venue or jurisdiction for purposes of this Final Judgment and authorizes Aimee H. Goldstein, Esq. of Simpson Thacher & Bartlett LLP to accept service of all process in this matter on its behalf; and

3. In the event Plaintiff withdraws its consent or if the proposed Final Judgment is not entered pursuant to this Stipulation, this Stipulation shall be of no effect whatever and the making of this Stipulation shall be without prejudice to any party in this or any other proceeding.

4. The entry of Final Judgment in accordance with this Stipulation settles, discharges, and releases any and all claims of Plaintiff, the United States, for civil penalties pursuant to Section 7A(g)(l) of the Clayton Act, 15 U.S.C. § 18a(g)(l), against Defendant and any officer, director, employee or trustee of Defendant, for failure to comply with Section 7A of the Clayton Act, 15 U.S.C. §18a, in connection with Defendant's 2003 acquisition of voting securities of John Hancock Financial, Inc.

Dated: March 31,2004

FOR THE DEFENDANT:

_______________/s/________________
Aimee H. Goldstein, Esq.
Simpson Thacher & Bartlett
LLP 425 Lexington Avenue
New York, NY 10017-3954
Counsel for Defendant

FOR THE PLAINTIFF:

_______________/s/________________
R. Hewitt Pate
Assistant Attorney General

_______________/s/________________
J. Bruce McDonald
Deputy Assistant Attorney General

_______________/s/________________
Mark J. Botti
Chief, Litigation I Section

_______________/s/________________
John R. Read
Assistant Chief, Litigation I Section

_______________/s/________________
J. Robert Kramer II
Director of Operations

_______________/s/________________
Barry L. Creech
DC Bar No. 421070

Attorneys, Antitrust Division
United States Department of Justice
1401 H Street, NW; Suite 4000
Washington, DC 20530
Telephone: (202)307-2110
Facsimile: (202) 307-5802

Attachments: 
Updated June 30, 2015