Non-Collusive Settlement Clause Samples

Non-Collusive Settlement. The instant settlement resulted from extensive, good-faith negotiations overseen by an experienced and impartial mediator, the ▇▇▇. ▇▇▇▇▇ ▇▇▇▇▇▇-Parrott (▇▇▇.). The parties neither discussed nor reached an agreement regarding the amount of any attorneys’ fees until an agreement was reached as to the settlement’s other material terms. The only benefits Plaintiff will receive for his settlement of the Plaintiff Settlement Class’s claims are: (1) the same relief as any other class member will receive; and (2) such incentive award as may be ordered by the Court.