Calculation of Payments to Settlement Class Members. Each Settlement Class Member shall be entitled to a proportional share of the Net Settlement Fund. These proportional shares shall be based on the damage estimates of Class Counsel’s expert, who analyzed the payroll and timekeeping records produced by Defendants, which are presumed to be accurate, incorporated certain assumptions as to all Settlement Class Members, and calculated individual damages. Specifically, a Settlement Class Member’s proportional share shall be the result of that Settlement Class Member’s estimated damages divided by the total estimated damages of all Settlement Class Members and multiplied by the Net Settlement Fund. This method for calculating Settlement Awards shall be disclosed to the Court and Class Members as part of the settlement approval process. Within ten (10) days of the Court’s grant of preliminary approval of the Settlement Agreement, Class Counsel shall provide a spreadsheet, in Microsoft Excel format, to Defendants and the Settlement Administrator with estimated Settlement Awards for each Class Member. Within ten (10) days of the Court’s grant of final approval of the Settlement Agreement, Class Counsel shall provide a spreadsheet to Defendants and the Settlement Administrator with final Settlement Awards for each Settlement Class Member. Class Counsel shall use all reasonable efforts to ensure the accuracy of these calculations.
Calculation of Payments to Settlement Class Members. After all of the payments of the court- approved Attorneys’ Fees and Costs, the Class Representative Service Payments, the PAGA Payment, and the Settlement Administration Expenses are deducted from the Gross Settlement Amount, the remaining portion, the “Net Settlement Amount”, shall be distributed as Settlement Shares to the Participating Settlement Class Members. The Net Settlement Amount is estimated to be at least $ . The Settlement Administrator will pay a Settlement Share from the Net Settlement Amount to each Participating Settlement Class Member. The Settlement Share for each Participating Settlement Class Member will be calculated as follows:
