Gross Settlement Fund. “Gross Settlement Fund” is the Cash Fund and Gross Write-Offs.
Gross Settlement Fund. “Gross Settlement Fund” is the sum of the Cash Fund and the Gross Deficiency Waiver Amount.
Gross Settlement Fund. “Gross Settlement Fund” means One Million Eight Hundred and Five Thousand Dollars and Zero Cents ($1,805,000.00) paid by Defendant to Plaintiffs and Class Members to resolve their claims, inclusive of attorneys’ fees and expenses, Service Awards to Named Plaintiffs, and the Settlement Administrator’s fees and expenses.
Gross Settlement Fund. 9 Pursuant to this Settlement, Defendant shall pay a non-reversionary gross settlement amount 10 of Nine Hundred Thousand Dollars ($900,000) (hereafter “Gross Settlement Fund”). In the event 11 that the aggregate number of California Rule 23 Class members exceeds 800 individuals, the amount 12 of the Gross Settlement Fund shall be increased pro-rata for each additional class member.
Gross Settlement Fund. A payment to the Settlement Class of $375,000 (“Gross Settlement Fund”). This payment shall be used to satisfy the following: (1) the settlement awards to Qualified Claimants (hereafter, the “Settlement Awards”), (2) all employee-side payroll taxes and withholdings associated with and deducted from the Settlement Awards, (3) the service award to the named Plaintiff (hereafter, the “Service Award”), and (4) an award of settlement administration expenses (hereafter, the “Settlement Administration Expenses Award”), all as approved by the Court.
Gross Settlement Fund. Defendant agrees to pay Two Million Four Hundred Thirty 9 Thousand Dollars and Zero Cents ($2,430,000.00). This amount includes: (i) payments made to 11 enhancement awards (i.e., service payments) to the Class Representatives (of up to $7,500 each 12 for Representative Plaintiffs Xxxxx Xxxxx, Xxxxx Xxxxxxxx, Xxxxx Xxxxxx, Xxxxxx Xxxxxxxx, and 13 Xxxx Xxxxxx, and up to $2,500 for Representative Plaintiff Xxx Xxxxx); (iii) $15,000 for the release 14 of any PAGA claims that could be asserted; (iv) fees and expenses of the Settlement Administrator 15 (not to exceed $15,000); (v) Class Counsel’s approved attorneys’ fees (of up to $810,000); (vi) 16 Class Counsel’s approved litigation costs, and (vii) and all other claims for interest, fees, and costs. 17 Under no circumstances shall Defendant be required to pay anything more than the Gross 18 Settlement Amount, except that Defendant will separately pay the employer payroll and 19 employment taxes due for the wages payments made under this Agreement. Defendant shall fully 20 fund the Gross Settlement Fund to the Settlement Administrator within ten (10) calendar days of 21 the Effective Date. In no event will Defendant be liable for making any payments under this 22 Settlement, or for providing any relief to the California Settlement Class and/or the FLSA 23 Settlement Class, before the Effective Date of this Agreement.
Gross Settlement Fund. In consideration for the release of the claims of the Settlement Class against Defendants, Defendants agree to create a “Gross Settlement Fund” of Four Hundred Ten Thousand Dollars and 00/100 Cents ($410,000.00) to be paid by Defendants, as a full and complete settlement of all claims that were or could have been asserted based on the facts alleged in the Lawsuit. This Gross Settlement Fund constitutes a common fund for the payment of all claims hereunder, attorney’s fees and litigation costs to Class Counsel, settlement administration costs, the Class Representative's Enhancement Award, and the amount allocated to Private Attorneys General Act ("PAGA"). The Gross Settlement Fund does not include Defendants' share of the employer-side payroll taxes on the amount of the Settlement allocated to wages. The Settlement is non-reversionary, and the entire Gross Settlement Fund will be paid by Defendants. Defendants will receive a $35,000 credit in consideration for “Pick Up Stix” payments made by them prior to the mediation of this matter on August 23, 2021, such that Defendants will only be responsible for paying $375,000 in new money (in addition to employer-side payroll taxes) in accordance with the terms of this settlement agreement.
Gross Settlement Fund. The Parties have settled the Action for a maximum amount of $1,400,000 (the “Gross Settlement Fund”). The Gross Settlement Fund includes all potential monies to be paid by Defendant in connection with the Settlement, including, without limitation, all Service Awards, attorneys’ fees and costs, all interest, liquidated and/or multiple damages, penalties, all costs including costs of administration of the Settlement by a third-party claims administrator, and all employer-side payroll taxes.
Gross Settlement Fund. The settlement requires Defendants to pay a total of $385,000 to establish a Gross Settlement Fund. Under the settlement, at least $[XXXX] shall be distributed to the Settlement Class Members as compensation for releasing the claims resolved by the settlement as described above. This compensation is a substantial portion of the wages allegedly owed to Class Members as calculated by Class Counsel and their expert based on Defendants’ records.
Gross Settlement Fund. The term “Gross Settlement Fund” refers to the maximum payment X.X. Logistics will make under the Settlement to Plaintiff, Consent Plaintiffs, and Subsequent Class Members including attorneys’ fees. The total Settlement agreed upon is $725,000, and after attorneys’ fees, costs, and the class representative award, the Net Settlement Fund amount sits at $517,500.
