Fair Settlement Clause Samples

Fair Settlement. Plaintiffs and Plaintiffs’ Counsel, based on their own independent investigations and evaluations, have examined the benefits to be obtained under the terms of this Settlement Agreement and have considered the claims of Plaintiffs, the claims of the average Settlement Class Member, the risks associated with the continued prosecution of the Actions, and the likelihood of success on the merits of the Actions. Plaintiffs and Plaintiffs’ Counsel recognize and acknowledge the significant expense, length, difficulty, and uncertainty of continued proceedings necessary to prosecute the Actions against Defendants through trial and appeals. Plaintiffs and Plaintiffs’ Counsel have also considered the uncertain outcome and the risk of continued litigation, especially in complex litigation such as the Action, as well as the difficulties and delays inherent in any such litigation. Plaintiffs and Plaintiffs’ Counsel believe that, after considering all the circumstances, the proposed Settlement set forth in this Agreement is a just, fair, reasonable, and favorable recovery in the best interests of the Settlement Class and confers substantial benefits upon the Settlement Class.

Fair Settlement. Plaintiffs, Defendants, and their respective counsel believe and warrant that this Agreement reflects a fair, reasonable, and adequate settlement of the claims against Defendants and have arrived at this Agreement through arms-length negotiations, taking into account all relevant factors, current and potential.

Fair Settlement. Plaintiffs, Viega, and their respective counsel believe and warrant that this Agreement reflects a fair, reasonable, and adequate settlement of the claims against Viega and have arrived at this Agreement through arms-length negotiations, taking into account all relevant factors, current and potential.

Fair Settlement. Settlement Class Representative, Defendant, Settlement Class 15 Counsel, and Defen counsel believe that this Settlement reflects a fair, reasonable, and 16 adequate -length 17 negotiations, taking into account all relevant factors, current and potential, and is consistent with 18 public policy, and fully complies with applicable provisions of law. 19 AGREED TO AND ACCEPTED: 20 ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ 21 By: 22 Dated: 23 25 ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ Settlement Class Representative PROVEN STAFFING CONSULTANTS, LLC Dated: By: 26 Its: DocuSign Envelope ID: 2860045C-CB3E-4F32-8D3B-E9EB6D818914 1 APPROVED AS TO FORM. 2 4 Dated:7/7/2022 | 1:14 PM PDT 7 8 9 Dated:7/7/2022 | 3:47 PM PDT 11 12 ▇▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇, P.C. By: ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ Avi Kreitenberg Settlement Class Counsel LAW OFFICES OF ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇, P.C. By: ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇ Settlement Class Counsel ▇▇▇▇▇▇ ▇▇▇▇▇▇ KOSMO LLP 13 Dated: 14 07/07/2022 By: ▇▇▇▇▇ ▇. ▇▇▇ ▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ Attorneys for Defendant DocuSign Envelope ID: 2860045C-CB3E-4F32-8D3B-E9EB6D818914

Fair Settlement. The Parties and their respective counsel believe and warrant that this Settlement reflects a fair, reasonable, and adequate settlement of the Lawsuit and have arrived at this Settlement and this Agreement through arms-length negotiations, taking into account all relevant factors, current and potential and will so represent to the court. In addition, the mediator may execute a declaration supporting the Settlement and the reasonableness of this Settlement, and the Court may, in its discretion, contact the mediator to discuss the Settlement and whether or not the Settlement is fair and reasonable.

Fair Settlement. Subject to the confirmatory discovery discussion raised above, the Parties and their respective counsel believe and warrant that this Settlement reflects a fair, reasonable, and adequate settlement of the Action and have arrived at this Settlement through arms-length negotiations, taking into account all relevant factors, current and potential.

Fair Settlement. The Parties, Class Counsel and Defense Counsel believe and warrant that this Agreement reflects a fair, reasonable, and adequate settlement of the Action and have arrived at this Agreement through arms-length negotiations, taking into account all relevant factors, both current and potential. ▇▇▇▇▇ ▇▇▇▇▇▇▇ Plaintiff By: ▇▇▇▇ ▇▇▇▇▇▇, CEO Defendant Bear Valley Community Healthcare District 2/21/2023 Date Date February 27, 2023 DocuSign Envelope ID: 86E7C5F1-3A6A-43ED-9F42-1F4768971F43 You may be eligible to receive money from an employee class action lawsuit (“Action”) against Bear Valley Community Healthcare District (“Bear Valley”) for alleged wage and hour violations. The Action was filed by a former Bear Valley employee ▇▇▇▇▇ ▇▇▇▇▇▇▇ (“Plaintiff”) and seeks payment of (1) alleged unpaid wages, statutory penalties, interest, and attorneys’ fees and costs for a class of all non-exempt or hourly-paid employees (“Class Members”) who worked for Bear Valley during the Class Period (July 29, 2018 to ); and (2) civil penalties under the California Private Attorney General Act (“PAGA”) for all non-exempt employees who worked for Bear Valley during the PAGA Period (July 29, 2020 to ) (“Aggrieved Employees”). The proposed Settlement has two main parts: (1) a Class Settlement requiring Bear Valley to fund Individual Settlement Payments, and (2) a PAGA Settlement requiring Bear Valley to fund Individual PAGA Payments and pay penalties to the California Labor and Workforce Development Agency(“LWDA”). $ . Based on Bear Valley’s records, your Individual Settlement Payment is estimated to be (less withholding) and your Individual PAGA Payment is will depend on a number of factors. (If no amount is stated for your Individual PAGA Payment, then according to Bear Valley’s records you are not eligible for an Individual PAGA Payment under the Settlement because you did not work as a non-exempt employee during the PAGA Period.) The above estimates are based on Bear Valley’s records showing that you worked Workweeks during the Class Period and you worked PAGA Pay Periods during the PAGA Period. If you believe that you worked more Workweeks during the Class Period or PAGA Pay Periods during the PAGA Period, you can submit a challenge by the deadline date. See Section 4 of this Notice. The Court has already preliminarily approved the proposed Settlement and approved this Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether y...

Fair Settlement. Settlement Class Representative, Defendant, Settlement Class 15 Counsel, and Defendant’s counsel believe that this Settlement reflects a fair, reasonable, and 16 adequate settlement of the Action and have arrived at this Settlement through arm’s-length 17 negotiations, taking into account all relevant factors, current and potential, and is consistent with 18 public policy, and fully complies with applicable provisions of law. 19 AGREED TO AND ACCEPTED: 20 ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ 22 Dated:7/7/2022 | 2:46 PM PDT 24 25 By: ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇ Settlement Class Representative PROVEN STAFFING CONSULTANTS, LLC 1 are for the sole benefit of the Parties under this Settlement, and shall not be construed to confer any 2 right or to avail any remedy to any other person.

Fair Settlement. The Parties and their respective counsel believe and warrant that this Agreement reflects a fair, reasonable, and adequate settlement of Rutti II and have arrived at this Agreement through arms-length negotiations, taking into account all relevant factors, current and potential.