Motions for Preliminary Approval a. As soon as practicable, and in no event later than thirty (30) days after the Execution Date, unless otherwise extended by written agreement of the Parties, Class Plaintiffs, through Plaintiffs’ Counsel, shall submit to the Court a motion for Preliminary Approval of this Agreement. The Preliminary Approval motion shall include: (a) a proposed form of, method for, and date of dissemination of notice; (b) a proposed schedule for the filing of any motion for fees and expenses, the filing of a motion to approve finally this Agreement, and a final fairness hearing; and (c) a proposed form of order preliminarily approving this Agreement. The motion (and its exhibits) seeking Preliminary Approval, including the text of the items referred to in clauses (a) through (c) above shall be proposed by Class Plaintiffs, through Plaintiffs’ Counsel, subject to the agreement of GTL, which agreement shall not be unreasonably withheld. The Parties shall take all reasonable actions as may be necessary to obtain Preliminary Approval of this Agreement. Plaintiffs shall provide a copy of the Motion for Preliminary Approval to GTL for its review no later than five (5) days before the date of filing.
Motions for Preliminary Approval. As soon as practicable, and in no event later than fourteen (14) days after the execution of this Agreement, unless otherwise extended by written agreement of the Parties, Direct Purchaser Class Plaintiffs, through Interim DPP Lead Counsel, shall submit to the Court a motion for Preliminary Approval of this Agreement, seeking certification of the Direct Purchaser Settlement Class for settlement purposes. The Preliminary Approval motion shall include: (a) the proposed definition of the class for settlement purposes; (b) a proposed form of, method for, and date of dissemination of notice;
Motions for Preliminary Approval. As soon as practicable, and in no event later than fourteen (14) days after the Execution Date, unless otherwise extended by written agreement of the Parties, Direct Purchaser Class Plaintiffs, through Interim DPP Lead Counsel, shall submit to the Court a motion for Preliminary Approval of this Agreement, seeking certification of the Direct Purchaser Settlement Class for settlement purposes. The Preliminary Approval motion shall include: (a) the proposed definition of the class for settlement purposes; (b) a proposed form of, method for, and date of dissemination of notice; (c) a proposed schedule for the filing of any motion for fees and expenses, the filing of a motion to approve finally this Agreement, and a final fairness hearing; and (d) a proposed form of order preliminarily approving this Agreement and certifying the Direct Purchaser Settlement Class for settlement purposes. The motion (and its exhibits) seeking Preliminary Approval, including the text of the items referred to in clauses (a) through (d) above shall be proposed by Direct Purchaser Class Plaintiffs, through Interim DPP Lead Counsel, subject to the agreement of SII, which agreement shall not be unreasonably withheld. The Parties shall take all reasonable actions as may be necessary to obtain Preliminary Approval of this Agreement and certification of the Direct Purchaser Settlement Class for purposes of this Settlement only.
