Defendants’ Consideration. 7 In consideration for the promises of Plaintiffs set forth in this Agreement, Defendants agree 8 as follows:
Defendants’ Consideration. In consideration for the promises of Plaintiff set forth in Section III of this Settlement Agreement, infra, Defendants agree as follows:
Defendants’ Consideration. After Final Approval of the Agreement, the withdrawal of Plaintiffs’ Motion and supporting documents as agreed upon in Paragraph 1 of this Section, and USCIS’s receipt of all necessary payment information from Plaintiffs’ Counsel, Defendants shall pay $400,000.00 in full and complete satisfaction of any claims by Plaintiffs and Plaintiffs’ Counsel for costs, attorneys’ fees, and litigation expenses incurred in connection with the Action. The payment will be made by electronic funds transfer in accordance with payment information provided to Defendants’ Counsel by Plaintiffs’ Counsel, and under the normal processing procedures followed by the Department of the Treasury.
Defendants’ Consideration. Within sixty days of final approval of the Settlement Agreement and Release as to Attorneys’ Fees, Expenses, and Taxable Costs (“Settlement Agreement”) by the Court, U.S. Customs and Border Protection shall pay $3,832,052.00 in full and complete satisfaction of any claims by Plaintiffs and their attorneys for costs, attorneys’ fees, and litigation expenses, including any interest, 1 The individuals originally named as Defendants were public officers being sued in their official capacity who have ceased to hold office during the pendency of the Litigation. Their successors are named here. See Fed. R. Civ. P. 25(d). incurred in connection with the Litigation. The payment will be made by electronic funds transfer in accordance with instructions provided to Defendants’ counsel by one of the undersigned attorneys for Plaintiffs, and under the normal processing procedures followed by the Department of the Treasury.
