Assad v. Crutchfield et al *** Case Consolidated for Discovery; All Non-Dispositive filings to be made in Lead Case 24-cv-2496***

UNITED STATES DISTRICT COURT
DISTRICT OF KANSAS
Lead Case No. 2:24-cv-02496-EFM-ADM
Case No. 2:25-cv-02186-EFM-ADM
Plaintiff,
v.
KEVIN S. CRUTCHFIELD, et al.,
Defendants,
and
COMPASS MINERALS INTERNATIONAL,
INC.,
Nominal Defendant.
FABRIZIO MORELLI, derivatively on behalf of
COMPASS MINERALS INTERNATIONAL,
INC.,
GEORGE ASSAD, Derivatively on Behalf of
Nominal Defendant COMPASS MINERALS
INTERNATIONAL, INC.,
Plaintiff,
v.
KEVIN S. CRUTCHFIELD, et al.,
Defendants,
and
COMPASS MINERALS INTERNATIONAL,
INC.,
Nominal Defendant
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ORDER AND FINAL JUDGMENT
This matter came before the Court for hearing on February 20, 2026, to consider approval
of the proposed settlement (“Settlement”) set forth in the Stipulation and Agreement of Settlement
dated October 24, 2025 (the “Stipulation”). The Court has reviewed and considered all documents,
evidence, objections (if any), and arguments presented in support of or against 	the Settlement.
Good cause appearing therefore, the Court enters this Order and Final Judgment (the “Judgment”).
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that:
1. 	This Judgment incorporates by reference the definitions in the Stipulation, and all
capitalized terms used herein shall have the same meanings as set forth in the Stipulation.
2. 	This Court has jurisdiction over the subject matter of the Actions, including all
matters necessary to effectuate the Settlement, and over all Parties.
3. 	The Court finds that the notice of the Settlement was published and disseminated
in accordance with this Court’s Preliminary Approval Order. This Court further finds that the form
and content of the Notice, as previously preliminarily approved by the Court, and the means of
dissemination of the notice of the Settlement fully satisfied the requirements of Rule 23.1 of the
Federal Rules of Civil Procedure and the requirements of due process.
4. 	The Court hereby approves the Settlement set forth in the Stipulation and finds that
the Settlement is, in all respects, fair, reasonable, and adequate to each of the Parties, and further
finds that the Settlement is in the best interests of Compass Minerals International, Inc.
(“Compass” or the “Company”) and its stockholders.
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5. 	The Actions and all claims contained therein, as well as all of the Released Claims
against Released Persons, are dismissed with prejudice. The Parties are to bear their own costs,
except as otherwise provided below.
6. 	Upon the Effective Date, the Plaintiffs Releasing Parties shall be deemed to have,
and by operation of the Judgment shall have, fully, finally, and forever released, relinquished, and
discharged the Released Claims against the Released Persons. Plaintiffs Releasing Parties shall be
deemed to have, and by operation of the Judgment shall have, covenanted not to sue any Released
Persons with respect to any Released Claims, and shall be permanently barred and enjoined from
instituting, commencing, or prosecuting the Released Claims against the Released Persons except
to enforce the releases and other terms and conditions contained in the Settlement and/or this
Judgment.
7. 	Upon the Effective Date, the Released Persons shall be deemed to have, and by
operation of the Judgment shall have, fully, finally, and forever released, relinquished, and
discharged each and all of Defendants’ Released Persons from Defendants’ Released Claims. The
Released Persons shall be deemed to have, and by operation of the Judgment shall have,
covenanted not to sue Defendants’ Released Persons with respect to any of Defendants’ Released
Claims, and shall be permanently barred and enjoined from instituting, commencing, or
prosecuting Defendants’ Released Claims against Defendants’ Released Persons except to enforce
the releases and other terms and conditions contained in the Stipulation and/or this Judgment.
8. 	During the course of the litigation, all parties and their respective counsel at all
times complied with the requirements of Rule 11 of the Federal Rules of Civil Procedure, and all
other similar laws or statutes.
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9. 	The Court hereby approves the sum of eight hundred fifty thousand dollars
($850,000.00) for the payment of Plaintiffs’ Counsel’s attorneys’ fees and expenses in the Actions
(the “Fee and Expense Amount”) and finds that the Fee and Expense Amount is fair and
reasonable. No other fees, costs, or expenses may be awarded to Plaintiffs’ Counsel in connection
with the Settlement. The Fee and Expense Amount shall be distributed in accordance with the
terms of the Stipulation.
10. 	The Court hereby approves the service awards of one thousand five hundred dollars
($1,500.00) for each of the two Plaintiffs to be paid from Plaintiffs’ Counsel’s Fee and Expense
Amount in recognition of Plaintiffs’ participation and effort in the prosecution of the Actions.
11. 	Nothing 	in 	this 	Stipulation, 	or 	any 	other 	settlement-related 	documents 	or
communications, constitutes an admission that any claim which was brought or could have been
brought in the Actions has or lacks any merit whatsoever, or that Defendants have committed or
engaged in any violation of law or wrongdoing whatsoever.
12. 	Neither the Stipulation, nor any of its terms or provisions, nor entry of this
Judgment, nor any act performed or document executed pursuant to or in furtherance of the
Stipulation or the Settlement, may be construed as, or may be used as evidence of the validity of
any of the claims released herein or an admission by or against the Individual Defendants of any
fault, wrongdoing, or concession of liability whatsoever.
13. 	Defendants may file the Stipulation and/or the Judgment in any action that has or
may be brought against them in order to support a defense or counterclaim based on principles of
res judicata, collateral estoppel, release, good faith settlement, judgment bar, or reduction, or any
other theory of claim preclusion or issue preclusion or similar defense or counterclaim.
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14. 	Without affecting the finality of this Judgment in any way, this Court hereby retains
continuing jurisdiction with respect to implementation and enforcement of the terms of the
Stipulation.
15. 	Pursuant to Rule 23.1 of the Federal Rules of Civil Procedure, this Court hereby
finally approves the Stipulation and Settlement in all respects, and orders the Parties to perform its
terms to the extent the Parties have not already done so.
16. 	This Judgment is a final judgment, and the Court finds that no just reason exists for
delay in entering the Judgment in accordance with the Stipulation. Accordingly, the Clerk is hereby
directed to enter this Judgment forthwith in accordance with Rule 58 of the Federal Rules of Civil
Procedure.
IT IS SO ORDERED.
DATED: February 23, 2026
HONORABLE ERIC F. MELGREN
UNITED STATES DISTRICT JUDGE
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