Common use of Final Approval Order and Judgment Clause in Contracts

Final Approval Order and Judgment. 66. Plaintiffs’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the fees, costs, expenses, or Service Award application, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPE. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 66. PlaintiffsSettlement Class Representatives’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur, which shall be sufficiently far in advance to allow for the deadlines contemplated by this Settlement. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 30 days prior to the Objection DeadlineFinal Approval Hearing, Plaintiffs Class Counsel shall file a motion for final approval of the Settlement and an application a motion for attorneys’ fees, costs, and expenses and for Service Awards. Objectors, if any, shall file any response to Class Counsel’s motions no later than 17 days prior to the Final Approval Hearing. By no later than 14 10 days prior to the Final Approval Hearing, the Parties responses shall file any responses be filed, if any, to any objectionsfilings by objectors, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards shall be filed. At the Final Approval Hearing, the Court will consider Plaintiffs’ the motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. In the Court’s discretion, the Court also will may hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object objects to the Settlement or to the Settlement, Class Counsel’s application for attorneys’ fees, costs, expenses, or and/or Service Award applicationAwards, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57this Settlement. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPE. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6670. Plaintiffs’ motion Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion their Motion for final approval Final Approval of the Settlement Settlement, and an application for attorneys’ fees, costs, costs and expenses and for Service Awards. By Awards for the Class Representatives, no later than 14 45 days prior to before the Final Approval Hearing. At the Final Approval Hearing, the Parties shall file any responses to any objectionsCourt will hear argument on Plaintiffs’ Motion for Final Approval of the Settlement, and any replies in support of final approval of the Settlement and/or on Class Counsel’s application for attorneys’ fees, costs, and expenses and for the Service Awards. At Awards for the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsRepresentatives. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the Class Counsel’s application for attorneys’ fees, costs, expenses, expenses or the Service Award Awards application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6771. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and entering final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, expenses and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPENavy Federal. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss Enter judgment dismissing the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting any of the Released ClaimsClaims hereof, as set forth in Section XIbar and enjoin all Releasing Parties from pursuing any Released Claims against Navy Federal or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order, and retain jurisdiction over the enforcement of the Court’s injunctions; f. Release SPE Navy Federal and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Navy Federal, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, construe and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 661. Plaintiffs’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. The Settlement Administrator shall bear the obligation of mailing the CAFA notices. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement and an application a motion for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses responses, if any, to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards for each Class Representative. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards for each Class Representative. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the applications for attorneys’ fees, costs, and expenses, or and for Service Award applicationAwards, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57Section VII paragraph 4. 672. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, and expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEDefendant. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XIIX, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Defendant and the Released Parties from the Released Claims, as set forth in Section XIIX; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE Defendant and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6668. Plaintiffs’ motion Plaintiff’s Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Plaintiff shall file her Motion for Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement Settlement, and an application for attorneys’ fees, costs, and expenses and for Service Awards. By Award for the Class Representative, no later than 14 45 days prior to before the Final Approval Hearing. At the Final Approval Hearing, the Parties shall file any responses to any objectionsCourt will hear argument on Plaintiff’s Motion for Final Approval of the Settlement, and any replies in support of final approval of the Settlement and/or on Class Counsel’s application for attorneys’ fees, costs, and expenses expenses, and for the Service Awards. At Award for the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsRepresentative. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the Class Counsel’s application for attorneys’ fees, costs, expenses, or the Service Award application, provided the objectors filed objector(s) submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6769. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and entering final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the a Service AwardsAward. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPENavy Federal. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process satisfies due process requirements; d. Dismiss Enter judgment dismissing the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting any of the Released ClaimsClaims hereof, as set forth in Section XIbar and enjoin all Releasing Parties from pursuing any Released Claims against Navy Federal or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order, and retain jurisdiction over the enforcement of the Court’s injunctions; f. Release SPE Navy Federal and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Navy Federal, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6672. Plaintiffs’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a their motion for final approval Final Approval of the Settlement and an application for attorneys’ feesSettlement, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support inclusive of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses costs and for a Service AwardsAward for the Class Representatives, no later than 15 days before the last day of the Opt-Out Period. At the Final Approval Hearing, the Court will consider hear argument on Plaintiffs’ motion for final approval Final Approval of the Settlement, and on Class Counsel’s application for attorneys’ fees, costs, and expenses costs and for the Service AwardsAwards for the Class Representatives. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the Class Counsel’s application for attorneys’ fees, costs, expenses, and costs or the Service Award application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6773. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the costs and any Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEAward. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting any of the Released Claims, as set forth in Section XI; bar and enjoin all Releasing Parties from pursuing any Released Claims (defined below) against Defendant or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order; and retain jurisdiction over the enforcement of the Court’s injunctions; f. e. Release SPE Defendant and the Released Parties from the Released Claims, as set forth in Section XI; and g. f. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Defendant, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6670. Plaintiffs’ motion Plaintiff’s Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The No later than eighty (80) days before the Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection DeadlineHearing, Plaintiffs shall Plaintiff must file a motion for final approval of the Settlement and an application for attorneys’ fees, costs, fees and expenses costs and for a Service AwardsAward to the Class Representative. By Plaintiff shall file the Motion for Final Approval of the Settlement no later than 14 forty-five (45) days prior to before the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion hear argument on Plaintiff’s Motion for final approval Final Approval of the Settlement, and including Class Counsel’s application for attorneys’ fees, fees and costs, and expenses and for any Service AwardsAward for the Class Representative. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the fees, Class Counsel’s application for attorneys’ fees and costs, expenses, or the Service Award application, provided the objectors filed objector(s) submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6771. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and entering final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, fees and the costs and a Service AwardsAward. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEXxxxxxx Xxxxxx Bank. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process satisfies due process requirements; d. Dismiss Enter judgment dismissing the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting any of the Released ClaimsClaims hereof, as set forth in Section XIbar and enjoin all Releasing Parties from pursuing any Released Claims against Chelsea Groton Bank or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order, and retain jurisdiction over the enforcement of the Court’s injunctions; f. Release SPE Xxxxxxx Xxxxxx Bank and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Chelsea Groton Bank, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 66. PlaintiffsSettlement Class Representatives’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur, which shall be sufficiently far in advance to allow for the deadlines contemplated by this Settlement. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C U.S.C. § 1715. By no later than 21 30 days prior to the Objection DeadlineFinal Approval Hearing, Plaintiffs Class Counsel shall file a motion for final approval of the Settlement and an application Settlement. Class Counsel shall move for Court approval of attorneys’ fees, costs, and expenses and for Service Awards. By Awards no later than 14 days prior to the Objection Deadline. Objectors, if any, shall file any response to Class Counsel’s motions no later than 17 days prior to the Final Approval Hearing. By no later than 10 days prior to the Final Approval Hearing, the Parties responses shall file any responses be filed, if any, to any objectionsfilings by objectors, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards shall be filed. At the Final Approval Hearing, the Court will consider Plaintiffs’ the motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. In the Court’s discretion, the Court also will may hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) ), who object to the Settlement or to the feesand/or Class Counsel’s Fee Application, costs, expenses, or and/or Service Award applicationAwards, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57this Settlement. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPE. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6690. Plaintiffs’ motion Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing Plaintiffs shall be scheduled file their Motion for Award of Fees, Costs, and Service Award, no earlier later than 90 thirty (30) days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715Notice Deadline. By Plaintiffs shall file their Motion for Final Approval of the Settlement no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 fourteen (14) days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. 91. At the Final Approval Hearing, the Court will consider hear argument on and determine whether to enter a Final Approval Order granting Plaintiffs’ motion Motion for final approval Final Approval of the SettlementSettlement and Motion for Award of Fees, Costs, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAward. In the Court’s discretion, the Court also will may hear argument at the Final Approval Hearing from any Participating Settlement Class Members (or their counsel) who object to the Settlement or to the feesfee, costscost, expensesexpense, or Service Award application, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57above. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards92. The proposed Final Approval Order that will be filed with the motion attached to Plaintiffs’ Motion for final approval Final Approval shall be in a form agreed upon by Class Counsel and SPEDefendant. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudiceprejudice and without costs; e. Bar and enjoin the Releasing Parties Plaintiffs and all Participating Settlement Class Members from asserting any of the Released Claims, as set forth in Section XIXII hereof, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Defendant and the Released Parties from the Released Claims, as set forth in Section XIXII hereof; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE the Parties to this Agreement, including Plaintiffs, Defendant, all Participating Settlement Class Members, and all Settlement Class Members (including all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms. 93. In the event that the Court does not enter the Final Approval Order in a form substantially the same as submitted, as determined by the Parties, the Parties have the right to terminate this Agreement and the Settlement, per Section XIV below. While materiality remains subject to the Parties’ determination in their reasonable discretion, material changes shall not include any changes to the legal reasoning or format used by the Court to justify the substantive relief sought by the Final Approval Order. In the event that the Effective Date does not occur, the Final Approval Order is vacated or reversed, or the Settlement does not become final and binding, the Parties agree to request that the Court vacate any dismissal with prejudice.

Final Approval Order and Judgment. 661. Plaintiffs’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 Within 120 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection DeadlinePreliminary Approval, Plaintiffs shall file a motion for final approval of the Settlement and an application a motion for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses responses, if any, to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for a Service AwardsAward to the Class Representative. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards to the Class Representatives. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the application for attorneys’ fees, costs, expenses, or and expenses and Service Award applicationAwards, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57Section VII paragraph 4. 672. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, and expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEDefendants. A current version is attached hereto as Exhibit 4, but may be subject to modification with the consent of Class Counsel and Defendants prior to the Final Approval Hearing. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XIIX, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Defendants and the Released Parties from the Released Claims, as set forth in Section XIIX; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE Defendants and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 66. 14.1 The Plaintiffs’ motion Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occurdate and location. The Plaintiffs shall file their Motion for Final Approval Hearing shall be scheduled no earlier than 90 days after of the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By Settlement no later than 21 45 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to before the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion hear argument on the Motion for final approval Final Approval of the Settlement, and on Class Counsel’s application for attorneys’ fees, costs, fees and expenses costs and for the Service AwardsAwards for the Class Representatives. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to Class Counsel’s application for attorneys’ fees and costs or the fees, costs, expenses, or Service Award application, provided . If the objectors filed timely objections that meet all date or location of the requirements listed in Paragraphs 56 and 57Final Approval Hearing changes, that information will be included on the Settlement Website for the Settlement Class’s benefit. 67. 14.2 At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and final judgment thereon, and whether to approve Class Counsel’s request application for attorneys’ fees, costs, expenses, fees and costs and Service Awards for the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPERepresentatives. Such proposed Final Approval Order shall, among other things: a. 14.3 Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. 14.4 Determine that the Notice provided satisfied satisfies Federal Rule of Civil Procedure 23 and Due Process requirements; d. Dismiss the Action with prejudice; e. 14.5 Bar and enjoin the all Releasing Parties from asserting any of the Released Claims, as set forth in Section XI; bar and enjoin all Releasing Parties from pursuing any Released Claims against Defendant at any time, including during the pendency of any appeal from the Final Approval Order; f. 14.6 Release SPE and the Released Parties from the Released Claims, as set forth in Section XI; and g. 14.7 Reserve the Court’s continuing and exclusive jurisdiction over SPE the Parties to this Agreement, including Defendant, all Class Members, and all Settlement Class Members (including all objectors) , to administer, supervise, construe, construe and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 66. PlaintiffsSettlement Class Representatives’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur, which shall be sufficiently far in advance to allow for the deadlines contemplated by this Settlement. The Final Approval Hearing shall be scheduled no earlier than 90 135 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715entry of the Preliminary Approval Order. By no later than 21 100 days prior to after the Objection Deadlineentry of the Preliminary Approval Order, Plaintiffs Class Counsel shall file a motion for final approval of the Settlement and an application for a motion attorneys’ fees, costsexpenses, Service Awards, and expenses notice and for Service Awardsadministration costs. Objectors, if any, shall file any response to Class Counsel's motions no later than 114 days after the entry of the Preliminary Approval Order. By no later than 14 128 days prior to after the Final entry of the Preliminary Approval HearingOrder, the Parties responses shall file any responses be filed, if any, to any objectionsfilings by objectors, and any replies in support of final approval of the Settlement and/or Class Counsel’s application request for attorneys’ fees, costsexpenses, and expenses and for Service Awards, and/or notice and administration costs shall be filed. At the Final Approval Hearing, the Court will consider Plaintiffs’ the motion for final approval of the Settlement, and Class Counsel’s 's application for attorneys’ fees, costsexpenses, Service Awards, and expenses notice and for Service Awardsadministration costs. In the Court’s discretion, the Court also will may hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) ), who object to the Settlement or to the and/or Class Counsel’s request for attorneys’ fees, costs, expenses, or Service Award applicationAwards, and/or notice and administration costs, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57this Settlement. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPE. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6679. Plaintiffs’ motion Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for to schedule a scheduled date on which the Final Approval Hearing will occur. The Plaintiffs shall file their Motion for Final Approval Hearing shall be scheduled of the Settlement, inclusive of Service Awards for the Class Representative, no earlier later than 90 15 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 Opt-Out and Objection Deadlines (135 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval after entry of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service AwardsPreliminary Approval Order). By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, Class Counsel Fees and expenses and for Service AwardsCosts shall be filed no later than 75 days after the Preliminary Approval Order is entered. At the Final Approval Hearing, the Court will consider hear argument on Plaintiffs’ motion Motion for final approval Final Approval of the Settlement, including certification of the Settlement Class, and on Class Counsel’s application for attorneys’ fees, costsClass Counsel Fees and Costs, and expenses and on the Service Awards for Service Awardsthe Class Representatives. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any member of the Settlement Class Members (or their counsel) who object to the Settlement or to Class Counsel’s application for Class Counsel Fees and Costs or the fees, costs, expenses, or Service Award Awards application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6780. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order and Judgment certifying the Settlement Class and granting final approval Final Approval of the SettlementSettlement and final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, Class Counsel Fees and Costs and to approve the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPE. Such proposed Final Approval Order and Judgment shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided Program satisfied the requirements of Due Process requirementsand Tex. R. Civ. P. 42(e)(1)(B) ; d. Dismiss the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting any of the Released Claims, as set forth in Section XIClaims against Defendants or its affiliates at any time, including during the pendency of any appeal from the Final Approval OrderOrder and Judgment; e. Rule upon Class Counsel’s application for Class Counsel Fees and Costs, including stating its findings of fact and conclusions of law in support of its ruling; f. Rule upon the Service Awards for the Class Representatives; g. Retain jurisdiction over the enforcement of the Court’s injunctions; h. Release SPE Defendants and the Released Parties from the Released Claims, as set forth in Section XI; and g. i. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Defendants, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6680. Plaintiffs’ The Plaintiff’s motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the final approval hearing (“Final Approval Hearing Hearing”) will occur. The date requested for the Final Approval Hearing shall be scheduled no earlier than 90 days after set so as to comply with all applicable timing requirements of CAFA. Plaintiff and Class Counsel shall file their motion for Final Approval of the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By Settlement, application for attorneys’ fees, costs and expenses and for a Service Award for Plaintiff no later than 21 49 days prior to the Objection Deadline, Plaintiffs shall file a Final Approval Hearing. The motion for final approval Final Approval will request Final Approval of the Settlement consistent with the terms of this Agreement. 81. At the Final Approval Hearing the Court will hear argument on Plaintiff’s and an Class Counsel’s motion for Final Approval of the Settlement, application for attorneys’ fees, costs, and expenses and for a Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application Award for attorneys’ fees, costs, and expenses and for Service Awards. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsPlaintiff. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the feesfee, costscost, expenses, expense or Service Award application, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57. 67paragraph 70 above. At or following The Court at the Final Approval Hearing, the Court Hearing will determine whether to enter the Final Approval Order granting final approval Final Approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, expenses and the a Service AwardsAward. The proposed Final Approval Order that will be filed with the motion for final approval shall be substantially in a the form agreed upon by Settlement Class Counsel and SPEcounsel for Xxxxxx Bank. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is and its terms are fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss the Action with prejudiceprejudice and without costs; e. Bar and enjoin the Releasing Parties Plaintiff and all Settlement Class Members, who have not properly opted out, from asserting any of the Released Claims, as set forth in Section XIXVII, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Xxxxxx Bank and the Released Parties from the Released Claims, as set forth in Section XI; and XVII and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Xxxxxx Bank, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, construe and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6690. Plaintiffs’ motion Plaintiff’s Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Plaintiff shall file her Motion for Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement Settlement, and an application for attorneys’ fees, costs, and expenses and for Service Awards. By Award for the Class Representative no later than 14 days prior to 90 after Preliminary Approval of the Settlement. At the Final Approval Hearing, the Parties shall file any responses to any objectionsCourt will hear argument on Plaintiff’s Motion for Final Approval of the Settlement, and any replies in support of final approval of the Settlement and/or on Class Counsel’s application for attorneys’ fees, costs, and expenses and for the Service AwardsAward for the Class Representative. At One week prior to the Final Approval Hearing, the Court will consider Plaintiffs’ motion for Plaintiff may file supplemental briefing in support of final approval of the SettlementSettlement including, and Class Counsel’s application for attorneys’ feesbut not limited to, costs, and expenses and for Service Awardsany objections and/or opt-outs received. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the Class Counsel’s application for attorneys’ fees, costs, expenses, expenses or the Service Award application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6791. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the Settlement, Settlement and entering final judgment thereon and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, expenses and the a Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEAward. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss Provide for the future entry of judgment dismissing the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Allstate and the Released Parties from the Released Claims, as set forth in Section XI; and g. f. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Allstate, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, construe and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6647. Plaintiffs’ The Plaintiff’s motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs Plaintiff and Class Counsel shall file a their motion for final approval of the Settlement Settlement, and an their application for attorneys’ fees, costs, costs and expenses and for Service Awards. By Award no later than 14 15 days prior to the Objection Deadline and the Opt-Out Deadline. At the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of Court will hear argument on Plaintiff’s motion for final approval of the Settlement and/or Settlement, and on Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion Award for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsPlaintiff. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the fees, costs, expenses, or Service Award application), provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57paragraph 41 above. 6748. At or following The Court at the Final Approval Hearing, the Court Hearing will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, expenses and the Service AwardsAward. The proposed Final Approval Order that will be filed with attached to the motion for final approval shall be in a form agreed upon by Class Counsel and SPEcounsel for Georgia Waste. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties Plaintiff and all Settlement Class Members from asserting any of the Released Claims, as set forth in Section XIXV, including during the pendency of any appeal from the Final Approval Order; f. e. Release SPE Georgia Waste and the Released Parties from the Released Claims, as set forth in Section XIXV; and g. f. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Georgia Waste, all Settlement Class Members (including and all objectors) , to administer, supervise, construe, construe and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6667. Plaintiffs’ motion for preliminary approval of the Settlement will shall include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C U.S.C. § 1715. By no later than 21 36 days prior to the Objection Deadlineinitially scheduled Final Approval Hearing, Plaintiffs shall file a motion for final approval of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the fees, costs, expenses, or Service Award application, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards68. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEChase. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XIX, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Chase and the Released Parties from the Released Claims, as set forth in Section XIX; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE Chase and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 661. Plaintiffs’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 Within 120 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection DeadlinePreliminary Approval, Plaintiffs Plaintiff shall file a motion for final approval of the Settlement and an application a motion for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses responses, if any, to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards for each Class Representative. At the Final Approval Hearing, the Court will consider Plaintiffs’ Plaintiff’s motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards for each Class Representative. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the application for attorneys’ fees, costs, and expenses, or and for Service Award applicationAwards, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57Section VII paragraph 4. 672. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, and expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEDefendant a current version is attached hereto as Exhibit 7, but which may be subject to modification with the consent of Class Counsel and Defendant prior to the Final Approval Hearing. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss Confirm that the claims of the Class Representative and the Settlement Class Members asserted in the Action have been settled, resolved, and released by the Settlement Agreement with prejudiceno adverse finding and no admission of liability against the Defendant; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XIIX, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Defendant and the Released Parties from the Released Claims, as set forth in Section XIIX; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE Defendant and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 661. Plaintiffs’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing Class Counsel shall be scheduled no earlier than 90 file a motion for attorneys’ fees, costs and expenses, and Service Awards within thirty (30) calendar days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715Notice Deadline. By no later than 21 Within one-hundred-twenty (120) calendar days prior to after the Objection Notice Deadline, Plaintiffs shall file a motion for final approval of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service AwardsSettlement. By no later than 14 fourteen (14) calendar days prior to the Final Approval Hearing, the Parties shall file any responses responses, if any, to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards to the Settlement Class Representatives. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards to the Class Representatives. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the application for attorneys’ fees, costs, expenses, or and expenses and Service Award applicationAwards, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57Section VII paragraph 4 herein. 672. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, and expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEDefendant. A current version is attached hereto as Exhibit 3, but may be subject to modification with the consent of Class Counsel and Defendant prior to the Final Approval Hearing. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XIIX herein, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Defendant and the Released Parties from the Released Claims, as set forth in Section XIIX herein; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE Defendant and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6673. Plaintiffs’ motion Plaintiff shall file her Motion for preliminary approval Final Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection DeadlineSettlement, Plaintiffs shall file a motion for final approval inclusive of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, fees and expenses costs and for a Service AwardsAward for the Class Representative, no later than 30 days before the last day of the Opt-Out Period. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion hear argument on Plaintiff’s Motion for final approval Final Approval of the Settlement, and on Class Counsel’s application for attorneys’ fees, fees and costs, and expenses and for the Service AwardsAward for the Class Representative. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Sufficient Funds Fee Class Members and Retry Fee Class members (or their counsel) who object to the Settlement or to the fees, Class Counsel’s application for attorneys’ fees and costs, expenses, or the Service Award application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement or that are required by the Court. 6774. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and final judgment thereon, and whether to approve Class Counsel’s request application for attorneys’ fees, fees and costs, expenses, and the any Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEAward. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Sufficient Funds Fee Class and Retry Fee Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting any of the Released Claims, as set forth in Section XI; bar and enjoin all Releasing Parties from pursuing any Released Claims (defined below) against Defendant or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order; and retain jurisdiction over the enforcement of the Court’s injunctions; f. e. Release SPE Defendant and the Released Parties from the Released Claims, as set forth in Section XI; and g. f. Reserve the Court’s continuing and exclusive jurisdiction over SPE the Parties to this Agreement, including Defendant, all Sufficient Funds Fee Class and Retry Fee Class members, and all Settlement Class Members (including all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6668. Plaintiffs’ The Settlement Plaintiff’s motion for preliminary approval of the Settlement will shall include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C U.S.C. § 1715. By no later than 21 7 days prior to after the Objection Deadline, Plaintiffs Settlement Plaintiff shall file a motion for final approval of the Settlement and an application for attorneys’ fees, costs, and expenses and for the Service AwardsAward, and the Settlement Administrator shall post the same on the Settlement Website within two business days after said filing. By no later than 14 days prior to the Final Approval Hearing, the Settling Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the fees, costs, expenses, or Service Award application, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards69. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEthe Settling Defendants. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action Settlement Plaintiff’s claims with prejudiceprejudice as to all defendants; e. Bar and enjoin Release the Releasing Parties from asserting any of the Released Claims, as set forth in Section XI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Settling Defendants and the Released Parties from the Released Claims, as set forth in Section XI; and; f. Order the Clerk of Court to disburse to The Contingent from the Court Registry the balance of the GNR Deposit that remains as of the date of Final Approval, taking into account amounts disbursed pursuant in connection with a separate settlement with plaintiffs Xxx Xxxx and Dynamic, so that The Contingent may, immediately after the Effective Date, disburse those funds in accordance with the then-effective terms of the amended Grant Agreement between The Contingent and the Oregon Department of Administrative Services; g. Reserve the Court’s continuing and exclusive jurisdiction over SPE the parties and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6692. Plaintiffs’ motion Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing Plaintiffs shall be scheduled file their Motion for Award of Fees, Costs, and Service Award, no earlier later than 90 thirty (30) days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715Notice Deadline. By Plaintiffs shall file their Motion for Final Approval of the Settlement no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 fourteen (14) days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. 93. At the Final Approval Hearing, the Court will consider hear argument on and determine whether to enter a Final Approval Order granting Plaintiffs’ motion Motion for final approval Final Approval of the SettlementSettlement and Motion for Award of Fees, Costs, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAward. In the Court’s discretion, the Court also will may hear argument at the Final Approval Hearing from any Participating Settlement Class Members (or their counsel) who object to the Settlement or to the feesfee, costscost, expensesexpense, or Service Award application, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57above. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards94. The proposed Final Approval Order that will be filed with the motion attached to Plaintiffs’ Motion for final approval Final Approval shall be in a form agreed upon by Class Counsel and SPEDefendant. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class Classes for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudiceprejudice and without costs; e. Bar and enjoin the Releasing Parties Plaintiffs and all Participating Settlement Class Members from asserting any of the Released Claims, as set forth in Section XIXII hereof, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Defendant and the Released Parties from the Released Claims, as set forth in Section XIXII hereof; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE the Parties to this Agreement, including Plaintiffs, Defendant, all Participating Settlement Class Members, and all Settlement Class Members (including all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms. 95. In the event that the Court does not enter the Final Approval Order in a form substantially the same as submitted, as determined by the Parties, the Parties have the right to terminate this Agreement and the Settlement, per Section XIV below. While materiality remains subject to the Parties’ determination in their reasonable discretion, material changes shall not include any changes to the legal reasoning or format used by the Court to justify the substantive relief sought by the Final Approval Order. In the event that the Effective Date does not occur, the Final Approval Order is vacated or reversed, or the Settlement does not become final and binding, the Parties agree to request that the Court vacate any dismissal with prejudice.

Final Approval Order and Judgment. 6678. Plaintiffs’ motion Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion their Motion for final approval Final Approval of the Settlement Settlement, and an application for attorneys’ fees, costs, costs and expenses and for Service Awards. By Awards for the Class Representatives no later than 14 105 days prior to after preliminary approval. At the Final Approval Hearing, the Parties shall file any responses to any objectionsCourt will hear argument on Plaintiffs’ Motion for Final Approval of the Settlement, and any replies in support of final approval of the Settlement and/or on Class Counsel’s application for attorneys’ fees, costs, and expenses and for the Service AwardsAwards for the Class Representatives. At One week prior to the Final Approval Hearing, the Court will consider Plaintiffs’ motion for Plaintiffs may file supplemental briefing in support of final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members members (or their counsel) who object to the Settlement or to the Class Counsel’s application for attorneys’ fees, costs, expenses, expenses or the Service Award Awards application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57. 67the Agreement. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the Settlement, Settlement and entering final judgment thereon and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, expenses and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPE. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss Provide for the future entry of judgment dismissing the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Farmers and the Released Parties from the Released Claims, as set forth in Section XI; and g. f. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Farmers, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, construe and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6668. Plaintiffs’ motion Plaintiff’s Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Plaintiff shall file her Motion for Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement and an Settlement, inclusive of Class Counsel’s application for attorneys’ fees, costs, costs and expenses and for a Service Awards. By Award for the Class Representative, no later than 14 45 days prior to before the Final Approval Hearing. At the Final Approval Hearing, the Parties shall file any responses to any objectionsCourt will hear argument on Plaintiff’s Motion for Final Approval of the Settlement, and any replies in support of final approval of the Settlement and/or on Class Counsel’s application for attorneys’ fees, costs, and expenses and for the Service Awards. At Award for the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsRepresentative. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the Class Counsel’s application for attorneys’ fees, costs, expenses, expenses or the Service Award application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6769. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, expenses and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEAward. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting any of the Released Claims, as set forth in Section XI; bar and enjoin all Releasing Parties from pursuing any Released Claims against Capital One or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order; and retain jurisdiction over the enforcement of the Court’s injunctions; f. e. Release SPE Capital One and the Released Parties from the Released Claims, as set forth in Section XI; and g. f. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Capital One, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6668. Plaintiffs’ motion Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion their Motion for final approval Final Approval of the Settlement and an application for attorneys’ feesSettlement, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support inclusive of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses Class Counsel Fees and for Service AwardsAwards for the Class Representatives, no later than 15 days before the Final Approval Hearing. At the Final Approval Hearing, the Court will consider hear argument on Plaintiffs’ motion Motion for final approval Final Approval of the Settlement, and on Class Counsel’s application for attorneys’ fees, costs, and expenses Class Counsel Fees and for the Service AwardsAwards for the Class Representatives. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to Class Counsel’s application for Class Counsel Fees or for the fees, costs, expenses, or Service Award applicationAwards, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57this Agreement. 6769. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, Counsel Fees and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPE. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify Certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided Program satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting any of the Released Claims, as set forth in Section XI; bar and enjoin all Releasing Parties from pursuing any Released Claims against Defendants or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order; and retain jurisdiction over the enforcement of the Court’s injunctions; f. e. Release SPE Defendants and the Released Parties from the Released Claims, as set forth in Section XI; and g. f. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Defendants, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6677. The Plaintiffs’ motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the final approval hearing (“Final Approval Hearing Hearing”) will occur. The date requested for the Final Approval Hearing shall be scheduled no earlier than 90 days after set so as to comply with all applicable timing requirements of CAFA. Plaintiffs and Class Counsel shall file their motion for Final Approval of the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By Settlement, application for attorneys’ fees, costs and expenses and for Service Awards for Plaintiffs no later than 21 49 days prior to the Objection Deadline, Plaintiffs shall file a Final Approval Hearing. The motion for final approval Final Approval will request Final Approval of the Settlement consistent with the terms of this Agreement. 78. At the Final Approval Hearing the Court will hear argument on Plaintiffs’ and an Class Counsel’s motion for Final Approval of the Settlement, application for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application Awards for attorneys’ fees, costs, and expenses and for Service Awards. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the feesfee, costscost, expenses, expense or Service Award Awards application, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57. 67paragraph 67 above. At or following The Court at the Final Approval Hearing, the Court Hearing will determine whether to enter the Final Approval Order granting final approval Final Approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, expenses and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be substantially in a the form agreed upon by Settlement Class Counsel and SPEcounsel for M & I Bank. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is and its terms are fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss the Action with prejudiceprejudice and without costs; e. Bar and enjoin the Releasing Parties Plaintiffs and all Settlement Class Members, who have not properly opted out, from asserting any of the Released Claims, as set forth in Section XIXVI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE M & I Bank and the Released Parties from the Released Claims, as set forth in Section XIXVI; g. Discharge the supersedeas bond #105163445 referred to in paragraph 4 above; and g. h. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including M & I Bank, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, construe and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 661. Plaintiffs’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 Within 45 calendar days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection DeadlinePreliminary Approval, Plaintiffs shall file a motion for final approval of the Settlement and an application a motion for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 calendar days prior to the Final Approval Hearing, the Parties shall file any responses responses, if any, to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards to the Class Representatives. At the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards to the Class Representatives. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the application for attorneys’ fees, costs, expenses, or and expenses and Service Award applicationAwards, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57Section VIII herein. 672. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, and expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEDefendants’ counsel. A current version is attached hereto as Exhibit 4, but may be subject to modification with the consent of Class Counsel and Defendant’ counsel prior to the Final Approval Hearing. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XIIX herein, including during the pendency of any appeal from the Final Approval Order; f. Release SPE Defendants and the Released Parties from the Released Claims, as set forth in Section XIIX herein; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE Defendants and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6659. Plaintiffs’ motion Plaintiff’s Motion for preliminary approval Preliminary Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Plaintiff shall file the Motion for Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection Deadline, Plaintiffs shall file a motion for final approval of the Settlement Settlement, and an application for attorneys’ fees, costs, costs and expenses and for Service Awards. By Award for the Class Representative, no later than 14 45 days prior to before the Final Approval Hearing. At the Final Approval Hearing, the Parties shall file any responses to any objectionsCourt will hear argument on Plaintiff’ Motion for Final Approval of the Settlement, and any replies in support of final approval of the Settlement and/or on Class Counsel’s application for attorneys’ fees, costs, and expenses and for the Service Awards. At Award for the Final Approval Hearing, the Court will consider Plaintiffs’ motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsRepresentative. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members Member (or their counsel) who object objects to the Settlement or to the Class Counsel’s application for attorneys’ fees, costs, expenses, expenses or the Service Award application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6760. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and entering final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, expenses and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEApple FCU. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, adequate and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided Program satisfied Due due Process requirements; d. Dismiss Enter judgment dismissing the Action with prejudice; e. Bar and enjoin the all Releasing Parties from asserting pursuing any of the Released Claims, as set forth in Section XIClaims against Apple FCU or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order, and retain jurisdiction over the enforcement of the Court’s injunctions; f. Release SPE Apple FCU and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Apple FCU, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, construe and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 66. PlaintiffsSettlement Class Representatives’ motion for preliminary approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing , which shall be scheduled no earlier than 90 days after sufficiently far in advance to allow for the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715deadlines contemplated by this Settlement. By no later than 21 30 days prior to the Objection DeadlineFinal Approval Hearing, Plaintiffs Class Counsel shall file a motion for final approval of the Settlement and an application Settlement. Class Counsel shall move for Court approval of attorneys’ fees, costs, and expenses and for Service Awards. By Awards no later than 14 days prior to the Objection Deadline. Objectors, if any, shall file any response to Class Counsel’s motions no later than 17 days prior to the Final Approval Hearing. By no later than 10 days prior to the Final Approval Hearing, the Parties responses shall file any responses be filed, if any, to any objectionsfilings by objectors, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service AwardsAwards shall be filed. At the Final Approval Hearing, the Court will consider Plaintiffs’ the motion for final approval of the Settlement, and Class Counsel’s application for attorneys’ fees, costs, and expenses and for Service Awards. In the Court’s discretion, the Court also will may hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) ), who object to the Settlement or to the feesand/or Class Counsel’s Fee Application, costs, expenses, or and/or Service Award applicationAwards, provided the objectors filed timely objections that meet all of the requirements listed in Paragraphs 56 and 57this Settlement. 67. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval of the Settlement, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPE. Such proposed Final Approval Order shall, among other things: a. Determine that the Settlement is fair, adequate, and reasonable; b. Finally certify the Settlement Class for settlement purposes only; c. Determine that the Notice provided satisfied Due Process requirements; d. Dismiss the Action with prejudice; e. Bar and enjoin the Releasing Parties from asserting any of the Released Claims, as set forth in Section XI, including during the pendency of any appeal from the Final Approval Order; f. Release SPE and the Released Parties from the Released Claims, as set forth in Section XI; and g. Reserve the Court’s continuing and exclusive jurisdiction over SPE and all Settlement Class Members (including all objectors) to administer, supervise, construe, and enforce this Agreement in accordance with its terms.

Final Approval Order and Judgment. 6658. Plaintiffs’ Plaintiff shall file their motion for preliminary approval Final Approval of the Settlement will include a request to the Court for a scheduled date on which the Final Approval Hearing will occur. The Final Approval Hearing shall be scheduled no earlier than 90 days after the CAFA notices are mailed to ensure compliance with 28 U.S.C § 1715. By no later than 21 days prior to the Objection DeadlineSettlement, Plaintiffs shall file a motion for final approval inclusive of the Settlement and an application for attorneys’ fees, costs, and expenses and for Service Awards. By no later than 14 days prior to the Final Approval Hearing, the Parties shall file any responses to any objections, and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses costs and for a Service AwardsAward for the Class Representative, no later than 15 days after the last day of the Opt-Out Period, or on the date which the Court orders. At the Final Approval Hearing, the Court will consider Plaintiffs’ hear argument on Plaintiff’s motion for final approval Final Approval of the Settlement, and on Class Counsel’s application for attorneys’ fees, costs, and expenses costs and for the Service AwardsAwards for the Class Representative. In the Court’s discretion, the Court also will hear argument at the Final Approval Hearing from any Settlement Class Members (or their counsel) who object to the Settlement or to the Class Counsel’s application for attorneys’ fees, costs, expenses, and costs or the Service Award application, provided the objectors filed submitted timely objections that meet all of the requirements listed in Paragraphs 56 and 57the Agreement. 6759. At or following the Final Approval Hearing, the Court will determine whether to enter the Final Approval Order granting final approval Final Approval of the SettlementSettlement and final judgment thereon, and whether to approve Class Counsel’s request for attorneys’ fees, costs, expenses, and the costs and any Service Awards. The proposed Final Approval Order that will be filed with the motion for final approval shall be in a form agreed upon by Class Counsel and SPEAward. Such proposed Final Approval Order shall, among other things: a. i. Determine that the Settlement is fair, adequate, and reasonable; b. ii. Finally certify the Settlement Class for settlement purposes only; c. iii. Determine that the Notice provided satisfied satisfies Due Process requirements; d. Dismiss the Action with prejudice; e. iv. Bar and enjoin the all Releasing Parties from asserting any of the Released Claims, as set forth in Section XI; bar and enjoin all Releasing Parties from pursuing any Released Claims (defined below) against Defendant or its affiliates at any time, including during the pendency of any appeal from the Final Approval Order; and retain jurisdiction over the enforcement of the Court’s injunctions; f. v. Release SPE Defendant and the Released Parties from the Released Claims, as set forth in Section XI; and g. vi. Reserve the Court’s continuing and exclusive jurisdiction over SPE and the Parties to this Agreement, including Defendant, all Settlement Class Members (including Members, and all objectors) , to administer, supervise, construe, and enforce this Agreement in accordance with its terms.