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” is the Cash Fund and Gross Write-Offs.
Gross Settlement Fund. “Gross Settlement Fund” means Three Million Six Hundred Thousand Dollars and Zero Cents ($3,600,000.00) paid by Defendant to Plaintiffs and Class Members to resolve their claims, inclusive of attorneys’ fees and expenses, Service Awards to Named Plaintiffs, the Settlement Administrator’s fees and expenses, and any taxes which the Settlement Administrator is required to pay on SEPTA’s behalf on W-2 settlement proceeds.
Gross Settlement Fund. “Gross Settlement” shall mean the potential total settlement payment that may be paid by Defendants in connection with this Agreement which shall not exceed Five Million Seven Hundred Thousand Dollars.
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. “Gross Settlement Fund” means up to $4,135,000.00, the maximum amount Defendant has agreed to pay to settle the Litigation as set forth in 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. “Gross Settlement Fund” means the Nineteen Million Nine Hundred Fifty Thousand Dollars and Zero Cents ($19,950,000.00) transferred by the Company pursuant to Section 4 of this Settlement Agreement, including all interest earned xxxxxxx, to be held, invested, administered, and disbursed pursuant to this Agreement.
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. “Gross Settlement Fund” means Eight Hundred Thousand Dollars ($800,000.00), the amount that Defendants agree to pay and that is utilized for calculation and distribution purposes for complete and final resolution of the Action.
