Settlement Class Members “Settlement Class Members” shall mean all persons in the Class who do not exclude themselves pursuant to Section F, herein, and those who submit a Valid Claim.
Defendants “Defendants” means Xxxx X. XXXX, Acting Secretary of Homeland Security, in his official capacity; Xxxxxxx XXXX, Attorney General of the United States, in his official capacity; Xxxxxxx X. XXXXXXX, Deputy Director for ICE (Senior Official Performing the Duties of the Director, ICE), in his official capacity; Xxxxxxx X. XXXXXXXXXX, Senior Official Performing the Duties of the Director, USCIS, in his official capacity; Xxxx X. XXXXXX, Acting Commissioner of CBP, in his official capacity; and Xxxxx XXXXXXX, Director of EOIR, in his official capacity.
Defendant shall make a good faith effort to issue a final decision on Xx. Xxxxx’x claim, if appropriate, as soon as practicable.
To Class Counsel A Class Counsel Fees Payment of not more than %, which is currently estimated to be $ , and a Class Counsel Litigation Expenses Payment of not more than $ . XYZ will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ harmless, and indemnifies XYZ, from any dispute or controversy regarding any division or sharing of any of these Payments.
Settlement Class 2. Pursuant to Rule 23(e)(1)(B)(ii) of the Federal Rules of Civil Procedure, the Court preliminarily finds that the Court will likely find that the requirements of Federal Rules of Civil Procedure 23(a) and 23(b)(3) have been satisfied for settlement and judgment purposes only. As to the requirements of Rule 23(a) for settlement purposes only, (i) the Settlement Class provisionally certified herein likely exceeds 100,000 individuals, and joinder of all would be impracticable; (ii) there are questions of law and fact common to the Settlement Class; (iii) Class Representatives’ claims are typical of the claims of the Settlement Class they seek to represent for purposes of settlement; and (iv) Class Representatives are adequate representatives of the Settlement Class. As to the requirements of Rule 23(b)(3) for settlement purposes only, questions of law and fact common to the Settlement Class predominate over any questions affecting any individual Settlement Class Member, and a class action on behalf of the Settlement Class is superior to other available means of settling and disposing of this dispute.
Plaintiffs Dated: Xxxxx Xxxxxxx by and through her Successor in Interest Xxxxx Xxxxxxx Dated: 5/15/2023 Xxxxxx Xxxxx by and through his Successor in Interest Xxxxxx Xxxxx Dated: Xxxxxx Xxxxxxx by and through his Successor in Interest Xxxx Xxxxxxx Dated: Xxxxxx Xxxxxxxx Dated: Xxxxxxx Xxxxxxxx by and through his Successor in Interest Xxxxxx Xxxxxxxx Dated: Xxxxxxx Xxxxxxxx by and through her Guardian ad Litem Xxxxxx Xxxxxx DocuSign Envelope ID: 2AA3F8C9-7439-440A-84AC-030939959524
Defendant’s Guilty Plea The defendant agrees to and hereby does plead guilty to Count One of the indictment charging him with a violation of 18 U.S.C. § 371, that is, conspiracy. [A copy of the indictment setting forth the charge in Count One is incorporated by reference.] By entering into this plea agreement, the defendant admits that he knowingly committed this and is in fact guilty of this offense.
Notice to Class Members 8.4.1 No later than three (3) business days after receipt of the Class Data, the Administrator shall notify Class Counsel that the list has been received and state the number of Class Members, PAGA Members, Workweeks, and Pay Periods in the Class Data.
Participating Class Members The Administrator will send, by U.S. mail, a single check to every Participating Class Member (i.e., every Class Member who doesn’t opt-out) including those who also qualify as Aggrieved Employees. The single check will combine the Individual Class Payment and the Individual PAGA Payment.
Out of Class Pay On occasion, due to operational necessity, an employee may be required to perform a majority of essential duties of another classification with a higher salary range. In such cases, payment for out-of-class work shall be 5% above the regular base pay of the employee for all hours worked in the higher classification. Such pay shall be a minimum of the “A” step of the higher classification and no more than the maximum of the highest step of the higher classification. If the 5% increase falls between steps, the next higher step is used. Eligibility for out-of-class pay will be subject to the following conditions:
