Motion for Preliminary Approval and Certification of Settlement Class. No later than March 4, 2024, or some other deadline approved by the Court, and after execution of this Agreement, Plaintiffs shall file a motion with the Court (to which Defendants will not object) seeking (i) preliminary approval of the Settlement, including entry of a Preliminary Approval Order identical in all material respects to the form of the order attached hereto as Exhibit D, and (ii) for purposes of this Settlement only, modification (as indicated in this Settlement agreement) of the class certification definition approved by the Court on June 5, 2023 (ECF No. 92).
Motion for Preliminary Approval and Certification of Settlement Class. By no later than June 10, 2020, or such other date as agreed by the Parties and approved by the Court after execution of this Agreement, Plaintiff shall move the Court for (i) preliminary approval of the Settlement, including entry of an order substantially similar in all material respects to the form of the Preliminary Approval Order attached as Exhibit D, and (ii) for purposes of this Settlement only, conditional certification of the Settlement Class. Class Counsel shall share a draft of the Motion for Preliminary Approval with Defendant’s Counsel no later than five (5) business days before the date for filing. Defendant will not object to Plaintiff’s motion for preliminary approval and class certification, provided both are consistent with the terms of this Agreement.
Motion for Preliminary Approval and Certification of Settlement Class. As soon as is practicable after execution of this Agreement, Plaintiff shall move the Court (i) for preliminary approval of the Settlement, including entry of an order in a form to be agreed to by the Parties, and (ii) for purposes of this Settlement only, conditional certification of the Settlement Class.
