Payment to Named Plaintiff Clause Samples

Payment to Named Plaintiff. In return for the risk she incurred and the services she rendered to the Class Members and in consideration of the individual settlement agreement being executed by her, including a general release, the Named Plaintiff will be paid $500.00. In return for the risks they incurred and the services they rendered to the Class Members and in consideration of the individual settlement agreements being executed by them, including general releases, the Opt-In Plaintiffs will be paid $250.00 each (collectively, the “General Release Payments”). Pineapple House will not contest Class Counsel’s request for these General Release Payments. The amount of these General Release Payments will be deducted from the Maximum Settlement Amount as described above. Prior to receiving the General Release Payments, the Named Plaintiff and Opt-In Plaintiffs must first execute separate Supplemental Settlement Agreement and General Releases of all claims to be prepared by Defense Counsel, as set forth in detail herein. DocuSign Envelope ID: D4AAFC95-D46C-48A5-A05B-F62626F24110