Litigation Standstill. Class Plaintiffs shall cease all litigation activities against Xxxxx Farms in the Action except to the extent expressly authorized in this Settlement Agreement. Xxxxx Farms and Xxxxx Farms’ Counsel shall cease all litigation activities against Class Plaintiffs in the Action, except in connection with providing the Cooperation provided for in Section II(A). As is necessary to effectuate this Agreement, Class Plaintiffs will continue to name Xxxxx Farms as a defendant in any amended complaint filed in the Action before the Date of Final Judgment. For the avoidance of doubt, should Class Plaintiffs seek to depose former Xxxxx Farms employees on topics primarily related to their time of employment at Xxxxx Farms, this litigation standstill shall not apply to preclude such depositions, and Xxxxx Farms in its sole discretion shall be permitted to represent the interests of Xxxxx Farms and the former employee in the deposition and any related discovery practice. None of the foregoing provisions shall be construed to prohibit Class Plaintiffs from seeking appropriate discovery from non-settling Defendants, Unrelated Co-
Appears in 3 contracts
Samples: Settlement Agreement, Settlement Agreement, Settlement Agreement
Litigation Standstill. Class Plaintiffs shall cease all litigation activities against Xxxxx Xxxxxxxxx Farms in the Action except to the extent expressly authorized in this Settlement Agreement. Xxxxx Xxxxxxxxx Farms and Xxxxx Xxxxxxxxx Farms’ Counsel shall cease all litigation activities against Class Plaintiffs in the Action, except in connection with providing the Cooperation provided for in Section II(A). As is necessary to effectuate this Agreement, Class Plaintiffs will continue to name Xxxxx Xxxxxxxxx Farms as a defendant in any amended complaint filed in the Action before the Date of Final Judgment. For the avoidance of doubt, should Class Plaintiffs seek to depose former Xxxxx Xxxxxxxxx Farms employees on topics primarily related to their time of employment at Xxxxx Xxxxxxxxx Farms, this litigation standstill shall not apply to preclude such depositions, and Xxxxx Xxxxxxxxx Farms in its sole discretion shall be permitted to represent the interests of Xxxxx Xxxxxxxxx Farms and the former employee in the deposition and any related discovery practice. None of the foregoing provisions shall be construed to prohibit Class Plaintiffs from seeking appropriate discovery from non-settling Defendants, Unrelated Co-Co- Conspirators, former employees of Xxxxxxxxx Farms consistent with Section II(A)(2)(d), or other third parties.
Appears in 2 contracts
Samples: Settlement Agreement, Settlement Agreement