Maximum Settlement Amount. As consideration, Defendant agrees to pay a non- reversionary Maximum 200,000.00 in full and complete settlement of this matter, as follows:
A. The Parties agree to engage ILYM the Settlement.
B. The Maximum Settlement Amount shall be deposited with the Settlement Administrator as follows: (1) $100,000 deposited the later of thirty days following Final Approval, or February 2, 2022, and (2) $100,000 deposited six months from the date of Final Approval.
C. The Maximum Settlement Amount includes:
(1) All payments to the Settlement Class;
(2) All costs of the Settlement Administrator associated with the administration of the Settlement, which are anticipated to be no greater than $10,000.00. In the event the costs of Settlement Administration come in under $10,000.00, the difference will be added to the Net Settlement Amount;
(3) Up to $10,000.00 for the Class Representative Enhancement Payment to each Plaintiff in recognition of each contributions to the action and Plaintiffs service to the Settlement Class. Even in the event that the Court reduces the requested Class Representative Enhancement Payment, Plaintiffs and Settlement Class Members shall not have the right to revoke the Settlement for that reason, and it will remain binding. The Class Representative Enhancement Payments are in addition to the Class . In the event the Court reduces the Class Representative Enhancement Awards, the difference will be added to the Net Settlement Amount;
(4) Up to one-third of the Maximum which is currently estimated at $66,666.67 plus actual costs and expenses related to the action, which are not to exceed $15,000.00, as supported by declaration. Even in the event that the Court reduces the requested Plaintiffs and Settlement Class Members shall not have the right to revoke this Settlement for that reason, and it will remain binding. In the event the costs, the difference will be added to the Net Settlement Amount; and
(5) $20,000 of the Maximum Settlement Amount has been set aside by the Parties as PAGA civil penalties. Per Labor Code section 2699(i), 75% of such penalties, or $15,000, will be payable to the Labor & Workforce remaining 25%, or $5,000, will be payable pro rata to Settlement Class Members who worked during the PAGA Period as t based on their total pay periods worked during the PAGA Period. The PAGA Period is defined as August 6, 2019 through the earlier of the date of preliminary approval or August 2, 2021. Even if the Court reduces or increases the re...
Maximum Settlement Amount. As consideration, Defendants agree to pay a non- reversionary “Maximum Settlement Amount” of Three Hundred Sixty-Two Thousand Five Hundred Dollars and Zero Cents ($362,500.00) in full and complete settlement of the Action, as follows:
A. The Parties have agreed to engage Phoenix Settlement Administrators as the “Settlement Administrator” to administer this Settlement.
B. Defendants will fund the Maximum Settlement Amount within thirty (30) calendar days after the Effective Date, which shall be deposited with the Settlement Administrator and held in an established Qualified Settlement Fund (“QSF”).
C. This is a non-reversionary settlement. The Maximum Settlement Amount includes:
(1) All payments (including interest) to the Settlement Class members;
(2) All costs of the Settlement Administrator which are anticipated to be no greater than Twelve Thousand Dollars and Zero Cents ($12,000.00);
(3) Up to Five Thousand Dollars and Zero Cents ($5,000.00) for Plaintiff’s Class Representative Enhancement Payment in recognition for Plaintiff’s general release of claims, contributions to the Action, and Plaintiff’s service to the Settlement Class. In the event that the Court reduces or does not approve the requested Class Representative Enhancement Payment, Plaintiff shall not have the right to revoke the Settlement Agreement for that reason, and the Settlement Agreement will remain binding;
(4) Up to one-third (33.33%) of the Maximum Settlement Amount in Class Counsel’s attorneys’ fees (currently estimated at $120,833.33), plus actual verified costs and expenses incurred by Class Counsel related to the Action as supported by declaration, which are currently estimated to be no greater than Fifteen Thousand Dollars and Zero Cents ($15,000.00). In the event that the Court reduces or does not approve the requested Class Counsel attorneys’ fees or costs, Class Counsel shall not have the right to revoke the Settlement Agreement based on that reason, and the Settlement Agreement will remain binding; and
(5) Twenty Thousand Dollars and Zero Cents ($20,000.00) of the Maximum Settlement Amount has been set aside by the Parties as PAGA civil penalties. Per Labor Code § 2699(i), 75% of such penalties, or Fifteen Thousand Dollars and Zero Cents ($15,000.00), will be payable to the California Labor & Workforce Development Agency (“LWDA”), and the remaining 25%, or Five Thousand Dollars and Zero Cents ($5,000.00), will be payable to the Settlement Class members as the “PAGA Amount,”...
Maximum Settlement Amount. Defendant’s total payment under this Settlement is $125,000.00, and under no circumstances shall Defendants be required to pay more than this amount in settlement of this Action.
Maximum Settlement Amount. The aggregate amount of TJX’s payment obligation under this Settlement Agreement shall not in any event exceed $23,989,750 (the “Maximum Settlement Amount”), which amount is subject to reduction as provided in Section 3.4 below.
Maximum Settlement Amount. As consideration, Defendant agrees to pay a non- reversionary maximum amount (“Maximum Settlement Amount”) of $200,000.00 in full and complete settlement of this matter, as follows:
A. The Parties have agreed to engage ILYM Group, Inc. as the “Claims Administrator” to administer this Settlement.
B. The Maximum Settlement Amount shall be deposited with the Claims Administrator within thirty (30) days of the Court’s granting final approval of this Agreement, including the resolution of any appeal or objection process, or by April 19, 2024, whichever is later.
C. The Maximum Settlement Amount includes:
(1) All payments (including interest) to the Settlement Class;
(2) All costs of the Claims Administrator associated with the administration of the Settlement;
(3) The Class Representative’s Enhancement Payment;
(4) Class Counsel’s attorneys’ fees and actual costs and expenses related to the Lawsuit;
(5) $20,000.00 of the Maximum Settlement Amount has been set aside by the Parties as PAGA civil penalties. Per Labor Code Section 2699(i), 75% of such penalties, or $15,000.00, will be payable to the California Labor & Workforce Development Agency (“LWDA”) for its share of PAGA penalties as the “LWDA Payment,” and the remaining 25%, or $5,000.00, will be payable to the eligible members of the Settlement Class as the “PAGA Amount.”
D. Defendant shall pay the standard company share of payroll taxes on all wages paid as part of this Settlement Agreement separate and apart from the Maximum Settlement Amount.
Maximum Settlement Amount. Subject to the terms and conditions of this Agreement, the Maximum Settlement Amount, excluding payroll taxes, that Defendant are obligated to pay under this Settlement Agreement is Two Hundred Thousand Dollars ($200,000).
Maximum Settlement Amount. Defendants’ total aggregate payments under this Agreement shall under no circumstances exceed the Maximum Settlement Amount.
Maximum Settlement Amount. Subject to the other terms and conditions
Maximum Settlement Amount. “Maximum Settlement Amount” shall mean Eight Hundred Thirty-Five Thousand Dollars ($835,000.00) inclusive of all attorneys’ fees, litigation costs, claims administration fees, and incentive payments to Named Plaintiffs.
Maximum Settlement Amount. Defendants agree to pay a Maximum Settlement Amount of no more than One Million Seven Hundred and Seventy- Five Thousand Dollars ($1,775,000), subject to Section 9(B). Defendants shall pay Employer Payroll Taxes separately from, and in addition to, the Maximum Settlement Amount.
