Preliminary Approval Motion. “Preliminary Approval Motion” means the motion Plaintiffs file in support of the Court’s preliminary approval of the Settlement.
Preliminary Approval Motion. Not later than ten (10) court days after execution of this Agreement, Plaintiff shall file a motion seeking preliminary approval of this Settlement Agreement (the “Preliminary Approval Motion”), which shall include: (1) the proposed Notice;
Preliminary Approval Motion. As soon as practical, Plaintiffs will move the Court for entry of the Preliminary Approval Order, attached hereto as Exhibit B. The Preliminary Approval Order shall provide, inter alia, that:
Preliminary Approval Motion. As soon as practical after the execution of this Agreement, the Parties shall move the District Court for entry of the Preliminary Approval Order substantially in the form attached as Exhibit 4. Pursuant to the motion for preliminary approval, the Parties will request that:
Preliminary Approval Motion. On or before June 30, 2016, or by such other date as agreed upon by the Parties and approved by the Court, Plaintiffs will move the Court for entry of the Preliminary Approval Order, which shall specifically include provisions that: (a) preliminarily approve the Debt Collection Settlement reflected herein as fair, adequate and reasonable to the Debt Collection Settlement Class, and within the reasonable range of possible final approval; (b) conditionally certify the Debt Collection Settlement Class for settlement purposes only and appoint Class Counsel as counsel for the Debt Collection Settlement Class for settlement purposes only; (c) approve the forms of Class Notice and find that the Notice Program constitutes the best notice practicable under the circumstances, provides due and sufficient notice to the Debt Collection Settlement Class and fully satisfies the requirements of due process and Federal Rule of Civil Procedure 23; (d) direct that notice be provided to the Debt Collection Settlement Class, in accordance with this Agreement, within thirty (30) days following entry of the Preliminary Approval Order (the “Notice Deadline”); (e) establish a procedure for Debt Collection Settlement Class Members to object to the Debt Collection Settlement or exclude themselves from the Debt Collection Settlement Class; (f) set a deadline sixty (60) days after the Notice Deadline, after which no one shall be allowed to object to the Debt Collection Settlement or exclude himself or herself from the Debt Collection Settlement Class or seek to intervene (the “Opt-Out and Objection Deadline”); (g) approve the Claim Form and the claims process described herein; (h) set the Claim Period for the submission of Claims to end ninety (90) days after the Notice Deadline; (i) establish a deadline for Class Counsel to move the Court for an award of attorneys’ fees and costs to be paid to Class Counsel and for service awards to be paid to Plaintiffs; and (j) schedule a hearing to consider Final Approval of the Debt Collection Settlement, which shall be scheduled no earlier than thirty (30) days after the Opt-Out and Objection Deadline.
Preliminary Approval Motion. Plaintiff will move for an order conditionally certifying the Class for settlement purposes only, giving Preliminary Approval of the Settlement, setting a date for the Final Approval hearing, and approving the Class Notice.
Preliminary Approval Motion. Promptly following execution of this Settlement Agreement, and no later than May 20, 2019, Plaintiff will move the Court for entry of the Preliminary Approval Order, which shall specifically include provisions that: (1) preliminarily approve the settlement reflected herein as fair, adequate, reasonable, and within the reasonable range of possible final approval; (2) conditionally certify the Settlement Class for settlement purposes only and appoint Class Counsel as counsel for the Settlement Class and Plaintiff as Class Representative; (3) approve the form of Class Notice and find that the notice program set forth herein constitutes the best notice reasonable and practicable under the circumstances, is due and sufficient notice to the Settlement Class, and fully satisfies the requirements of due process and Federal Rule of Civil Procedure 23; (4) establish a procedure for Settlement Class Members to object to the settlement or exclude themselves from the Settlement Class, and set a date following entry of the Preliminary Approval Order, after which no one shall be allowed to object to the settlement or opt-out/exclude himself or herself from the Settlement Class or seek to intervene in the Action; (5) approve the Claim Form and the claims submission process described herein; (6) finally certify the Settlement Class; (7) pending final determination of whether the settlement should be approved, bar all persons in the Settlement Class, directly, on a representative basis, or in any other capacity from commencing or prosecuting against any of the Released Parties any action, arbitration, or proceeding in any court, arbitration forum, or tribunal asserting any of the Released Claims; (8) authorize the Parties, without further approval from the Court, to agree to and adopt such conforming amendments, modifications, and expansions of the Settlement Agreement and its implementing documents (including all exhibits to this Settlement Agreement) so long as they are consistent in all material respects with the terms of the Final Approval Order and Judgment; (9) pending final determination of whether the settlement should be approved, stay all proceedings in the Action, except those related to the effectuation of the settlement; and
Preliminary Approval Motion. As soon as practicable after the execution of this Agreement, Plaintiffs’ Counsel shall move the Court for an order substantially in the form of Exhibit C hereto, which shall specifically include provisions that: (a) preliminarily approve the Settlement memorialized in this Agreement as fair, reasonable and adequate; (b) certify the Settlement Classes as defined herein for settlement purposes only; (c) set a date for a Final Approval Hearing; (d) approve the proposed Class Notice that is attached as Exhibit A, and authorize its dissemination to Settlement Class Members; (e) set deadlines consistent with this Agreement for mailing of the Class Notice, opting out of or objecting to the Settlement, and filing papers in connection with the Final Approval Hearing; (f) appoint Settlement Class Representatives as class representatives and Class Counsel as counsel for the Settlement Classes; and (g) approve the appointment of the Settlement Administrator.
Preliminary Approval Motion. At the earliest practicable time, Plaintiff shall file with the Court a Motion for Order Granting Preliminary Approval and supporting papers, which shall include this Settlement Agreement. Any dispute regarding forms of notices and other documents necessary to implement the Settlement contained in the Stipulation, if not timely resolved among the Parties, shall be referred to the Court. The Parties shall seek a prompt hearing date to obtain preliminary approval of the Settlement.
Preliminary Approval Motion. The Preliminary Approval Motion shall include:
