Motion for Final Approval of Class Action Settlement. On the date set by the Court in its Preliminary Approval Order, Plaintiffs shall have filed a motion (the “Final Approval Motion”) for a Final Approval Order. The Final Approval Motion shall seek the Court’s finding that the Final Approval Order is a final judgment disposing of all claims and all Parties.
Motion for Final Approval of Class Action Settlement. On the date set by the Court in its Preliminary Approval Order, Plaintiffs shall have filed a motion (the
Motion for Final Approval of Class Action Settlement. Pursuant to the schedule set by the Court in its Preliminary Approval Order and at least twenty-one (21) days before the Final Approval Hearing, Class Counsel shall file a motion and supporting papers requesting that the Court grant final approval of this Settlement Agreement and for entry of a Final Approval Order agreed to by the Parties:
a. Certifying the Settlement Class for settlement purposes only;
b. Finally approving the Settlement Agreement as fair, reasonable, and adequate;
c. Finding that the Notice Plan complied with the Due Process Clause, and was fair, adequate, and sufficient, as the best practicable notice under the circumstances, and reasonably calculated to apprise Settlement Class Members of the Litigation, the Settlement Agreement, their objection rights, and their opt-out rights;
d. Listing all opt-outs, if any;
e. Finding that the Class Members who have not opted out are bound the Settlement Agreement and all of its terms;
f. Authorizing the Parties to implement the terms of the Settlement Agreement;
g. Releasing the Released Parties from the Released Claims; and
h. Retaining jurisdiction relating to the administration, implementation, enforcement, and interpretation of the Settlement Agreement and the Final Approval Order.
