Common use of Preliminary Approval Clause in Contracts

Preliminary Approval. The Parties will move the Court for entry of the Preliminary Approval Order in substantially the form attached as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable to the Settlement Class, and within the reasonable range of possible final approval; (b) certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for the 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 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 Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approved, bar and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not object to these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that, under Fed. R. Civ. P. 23(c)(2), the forms of Class Settlement Notice and find that the Notice Program constitutes the best notice practicable under the circumstances, provides due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and complies fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and any other applicable law; Cause the Settlement Administrator to send by first-class mail and/or e- mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper; Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) days after entry of the requirements Preliminary Approval Order, by any Former Participants, Beneficiaries, or Alternate Payees who do not have Active Accounts, who wish to receive the benefits of due process and Federal Rule of Civil Procedure 23this Settlement; (d) direct that notice be provided to the Settlement ClassProvide that, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred and forty (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14140) days after the Opt-Out date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether: (a) the Court should approve the Settlement as fair, reasonable, and Objection Deadline adequate; (b) the Court should enter the Final Approval Order; and provide (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that this hearing any objections to any aspect of the Settlement Agreement shall be heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any notice of intent to participate or supporting documents must be filed or postmarked at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate fifteen days (15) before the Fairness Hearing; Provide that any party may file a response to an objection by a Class Member at least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, from time to time without further direct notice to the Settlement ClassClass Members, other than by notice to Class Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not object to these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice to of the Settlement Fairness Hearing and of the rights of all Class Members, and comply fully satisfies with the requirements of due process Fed. R. Civ. P. 23, the Constitution of the United States, and Federal Rule of Civil Procedure 23any other applicable law; (d) direct that notice be provided to Cause the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members Administrator to object to send by first-class mail the Settlement or exclude themselves from Notice to each Class Member identified by the Settlement ClassAdministrator based upon the data provided by the Plan’s Recordkeeper; Provide that, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred twenty (120) calendar days after the date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether (a) the Court should approve the Settlement as fair, reasonable, and adequate; (hb) pending final determination the Court should enter the Final Order; and (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that any objections to any aspect of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by heard, and any Settlement Class Member or any other Personpapers submitted in support of said objections shall be considered, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly at the Fairness Hearing if they have been filed with this Court, noticed and served in accordance validly with the governing rules of procedure; (k) schedule a hearing on Final Approval Clerk of the SettlementCourt and copies provided to Class Counsel and Defense Counsel. To be filed validly, which shall the objection and any notice of intent to participate or supporting documents must be scheduled no earlier than filed at least fourteen (14) calendar days after prior to the Opt-Out scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and Objection Deadline and provide serve a notice of intent to participate within the time limitation set forth above; Provide that this hearing any party may file a response to an objection by a Class Member at least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, from time to time without further direct notice to the Settlement ClassClass Members, other than by notice to Class Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will 67. As soon as practicable following execution of this Agreement, Class Counsel shall move the Court for entry of the Preliminary Approval Order (substantially in substantially the form attached as of Exhibit CC hereto), which shall specifically include provisions thatfor the purposes of, among other things: (a) preliminarily approve approving the Settlement reflected memorialized in this Agreement as sufficiently fair, adequate and reasonable to the Settlement Class, and being within the reasonable range of possible final approvalreasonableness such that the Class Notice should be provided pursuant to this Agreement; (b) certify finding that the requirements for provisional certification of the Settlement Class have been satisfied; (c) certifying the Settlement Class as defined herein for settlement purposes only; (d) setting a date for a Final Approval Hearing; (e) approving the proposed Class Notice that is attached hereto as Exhibit A, and authorizing its dissemination to Settlement Class Members in accordance with the terms of this Agreement; (f) determining that the notice of the Settlement and of the Final Approval Hearing, as set forth in this Agreement, complies with all legal requirements, including but not limited to the Due Process Clause of the United States Constitution; (g) providing that any Objection by any Settlement Class Member to the certification of the Class and the proposed Settlement set forth in this Agreement, and/or the entry of the Final Approval Order, shall be heard and any papers submitted in support of said Objection shall be considered by the Court at the Final Approval Hearing only if, on or before the date(s) specified in the Class Notice and appoint Plaintiffs Preliminary Approval Order, such objector submits to the Court a written objection, and otherwise complies with the requirements in Paragraph 85 of this Agreement; (h) establishing dates by which Class Counsel shall file and serve all papers in support of the application for final approval of the Settlement, by which Class Counsel shall file and serve all papers in support of the Fee Application and the Service Payment Application, and by which the Parties shall file and serve all papers in response to any valid and timely Objections; (i) providing that all Settlement Class Members will be bound by the Final Approval Order; (j) providing that persons in the Settlement Class wishing to exclude themselves from the Settlement will have until the date specified in the Class Notice and the Preliminary Approval Order to submit a valid written exclusion or opt-out request to the Settlement Administrator; (k) providing a procedure for persons in the Settlement Class to request exclusion or opt out from the Settlement; (l) directing the Parties, pursuant to the terms and conditions of this Agreement, to take all necessary and appropriate steps to establish the means necessary to implement the Settlement; (m) setting 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; (n) appointing Settlement Class Representatives as class representatives and Class Counsel as counsel for the Settlement Class for settlement purposes onlyClass; and (co) approve approving the forms appointment of Class Notice and find that the Notice Program constitutes the best notice practicable under the circumstances, provides due and sufficient notice to the Settlement Class and fully satisfies Administrator. For purposes of Settlement only, Defendants will not oppose the requirements Preliminary Approval Order or the certification, pursuant to Fed. R. Civ. P. 23(b)(3), of due process and Federal Rule of Civil Procedure 23; (d) direct that notice be provided to the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approved, bar and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E..

Preliminary Approval. The Parties will Promptly upon full execution of this Settlement Agreement, Plaintiffs shall move the Court for entry of the Preliminary Approval Order substantially in substantially the form attached as of Exhibit CJ to this Settlement Agreement, which shall specifically include provisions thatfor the purposes of, among other things: (a) preliminarily approve approving the Settlement reflected settlement memorialized in this Settlement Agreement as sufficiently fair, adequate and reasonable to such that Notice should be provided in accordance with the terms of this Settlement Class, and within the reasonable range of possible final approvalAgreement; (b) certify finding that the requirements for provisional certification of the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for the Settlement Class for settlement purposes onlyhave been satisfied; (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 certifying the Settlement Class and fully satisfies the requirements of due process and Federal Rule of Civil Procedure 23as defined herein; (d) direct that notice be provided to the Settlement Class, in accordance with this Agreementsetting a date for a Fairness Hearing; (e) establish a procedure for approving the proposed Notice program described in Section VI herein (including the proposed forms and methods of notice), and directing its dissemination to Settlement Class Members to object to in accordance with the terms of this Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection DeadlineAgreement; (f) approve determining that the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approvedNotice program, bar and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Settlement Agreement, complies with all legal requirements, including but not limited to the Due Process Clause of the United States Constitution; (g) approving the proposed Claim Form and Claims Process, and directing that the Claim Process be implemented pursuant to the terms of this Settlement Agreement; (jh) provide providing that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted any objections by any Settlement Class Member to this Settlement Agreement, the entry of the Final Order and Judgment, or to Settlement Class Counsel’s request for attorneys’ fees, costs, or service awards, shall be heard and any other Person, other than as may papers submitted in support of said objections shall be directed considered by the Court upon at the Fairness Hearing only if, on or before the date(s) specified in the Notice and Preliminary Approval Order, such objector submits to the Court a proper showing seeking such discovery by motion properly filed with this Courtwritten objection, noticed and served in accordance otherwise complies with the governing rules requirements for objections set forth in Section VIII of procedurethis Settlement Agreement; (ki) schedule a hearing on Final Approval establishing dates by which Settlement Class Counsel shall file and serve all papers in support of final approval of the SettlementSettlement and in support of their application for attorneys’ fees, costs, and service awards, and by which the Parties shall be scheduled no earlier than fourteen (14) days after the Opt-Out file and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES serve all papers in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from any objections; (j) providing that all Settlement Class Members on or after who do not submit timely and valid requests for exclusion will be bound by the date of preliminary approval substantially in the form attached as Exhibit E.Final Order and Judgment;

Preliminary Approval. The Parties will 2.01 Within ten (10) days after the execution of this Settlement Agreement by Class Counsel and Defendants, Class Counsel shall move the Court to enter an order for entry of the Preliminary Approval Order substantially in substantially the form of Exhibit B attached as Exhibit Chereto (“Preliminary Approval Order”), which order shall specifically include provisions that: (a) preliminarily approve the Settlement reflected memorialized in this Settlement Agreement as sufficiently fair, adequate reasonable, and reasonable to adequate, including the material terms of this Agreement; (b) provisionally approve the Settlement Class, and within the reasonable range of possible final approvalas defined herein, for settlement purposes only; (bc) certify conditionally designate Representative Plaintiffs as the representatives of the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for the 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 Settlement Class and fully satisfies the requirements of due process and Federal Rule of Civil Procedure 23Class; (d) direct that notice be provided to the Settlement Class, in accordance with this Agreementset a date for a final approval hearing (“Court Approval Hearing”); (e) establish a procedure for Settlement approve the proposed Class Members to object Notice in the form attached hereto as Exhibit C and authorize its dissemination to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection DeadlineClass Members; (f) approve continue the Claim Form substantially stay of all proceedings and deadlines in the form attached as Exhibit B and Action, excepting only those proceedings related to the claims process described in this AgreementSettlement, pending the Final Approval Hearing; (g) pending final determination set deadlines consistent with this Agreement for mailing of whether the Class Notice, the filing of objections, the filing of motions, the submission of requests for exclusion from the Class, and the filing of papers in connection with the Court Approval Hearing; (h) appoint and approve the Settlement should be approved, bar Administrator; and (i) prohibit and preliminarily enjoin Representative Plaintiffs, all Settlement Class MembersMembers (excepting those who are Successful Opt-Outs), directlyClass Counsel, on a representative basis or in any other capacity, and Plaintiffs’ Counsel from commencing, prosecuting, intervening in, or participating as a plaintiff or class member assisting in any action, arbitration, lawsuit against the Released Persons that asserts or proceeding in any court, arbitration forum or tribunal asserting any purports to assert matters within the scope of the Released Claims against any Release during the time between entry of the Released Parties; (h) pending Preliminary Approval Order and final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with regarding whether to finally approve the Settlement in this Court, noticed and served in accordance with Action. Defendants agree not to oppose the governing rules of procedure; (k) schedule a hearing on Final Approval entry of the SettlementPreliminary Approval Order, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval provided it is substantially in the form of Exhibit B attached as Exhibit E.hereto. Without implication or limitation, Defendants’ agreement not to oppose the entry of the Preliminary Approval Order shall not be an admission or concession by Defendants (or any of them) that a class was appropriate in the Action or would be appropriate in any other matter, and/or that any relief was appropriate in the Action, for litigation or for settlement purposes, or would be appropriate in any other matter.

Preliminary Approval. The Parties will move Within a reasonable time after execution of this Settlement Agreement by the Parties, Plaintiff shall apply to the Court for the entry of the Preliminary Approval Order in substantially the form attached as Exhibit C, which shall specifically include provisions thatan Order: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable to the Settlement Class, and within the reasonable range of possible final approval; (b) certify Conditionally certifying the Settlement Class for settlement purposes only of this Settlement Agreement; Appointing Xxxx X. Xxxxxx of Xxxxxx Law Group, APC and appoint Plaintiffs Xxxxx X. Xxxxxx, Xxxxx Xxxxx, Xxxxxxxxx Xxxxxx, and Xxxxxx Xxxxxx of Xxxxxx Law, APC as class representatives and Class Counsel Counsel; Appointing Xxxxxxxxx Xxxxxxxx as counsel Class Representative for the Settlement Class for settlement purposes onlyClass; Approving Phoenix Settlement Administrators as Settlement Administrator; Preliminarily approving this Settlement Agreement and its terms as fair, reasonable, and adequate; Approving the form and content of the Notice Packet (c) approve which is comprised of the forms Notice of Pendency of Class Action and Settlement and Notice and find that the Notice Program constitutes the best notice practicable under the circumstancesof Individual Settlement Award, provides due and sufficient notice to the Settlement Class and fully satisfies the requirements drafts of due process and Federal Rule of Civil Procedure 23; (d) direct that notice be provided to the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Classwhich are attached collectively hereto as Exhibit A), and set directing the Opt-Out and Objection Deadlinemailing of same; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approved, bar and preliminarily enjoin Staying all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of until Final Approval; and Scheduling a Final Approval hearing. The Preliminary Approval Order shall be substantially the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks same as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.C. Class Counsel must draft the preliminary approval papers and give Defendants’ counsel a draft of the papers to review at least five (5) calendar days before the filing deadline. Defendants shall be permitted, but not required, to file their own brief or statement in support of Preliminary Approval. Defendants agree not to file an opposition to the Motion for Preliminary Approval or Motion for Final Approval.

Preliminary Approval. The Parties will move As soon as reasonably possible and subject to any relevant Court Order, the Class Representatives, through Class Counsel, shall file with the Court a motion seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve C. Defendants will not object to the Settlement reflected relief sought in this Agreement motion even if they do not agree with all averments of the pleadings filed in support of Plaintiffs’ Motion for Preliminary Approval of Settlement, so long as sufficiently fair, adequate and reasonable they are consistent with the terms herein. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice to of the Settlement Fairness Hearing and of the rights of all Class Members, and comply fully satisfies with the requirements of due process Fed. R. Civ. P. 23, the Constitution of the United States, and Federal Rule of Civil Procedure 23any other applicable law; (d) direct that notice be provided to Cause the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members Administrator to object to send by first-class mail the Settlement or exclude themselves from Notice to each Class Member identified by the Settlement Class, and set Administrator based upon the Opt-Out and Objection Deadline; (f) approve data provided by the Claim Form substantially Plan’s Recordkeeper. With respect to current participants in the form attached as Exhibit B and Plans, who are either active employees or who have provided the claims process described in this Agreementrecordkeeper with an email address, Notice may be sent by email only; (g) Provide that, pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than ninety (90) calendar days after the date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether (a) the Court should approve the Settlement as fair, reasonable, and adequate; (hb) pending final determination the Court should enter the Final Order; and (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that any objections to any aspect of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court. To be filed validly, the objection and any Settlement notice of intent to participate or supporting documents must be filed at least (14) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file with the Clerk of the Court a notice of intent to participate within the time limitation set forth above; Provide that any party may file a response to an objection by a Class Member or any other Personat least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, without further direct notice to the Class Members, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement ClassClass Counsel, be adjourned or continued or adjourned by order of the CourtCourt and/or be heard by Zoom or other United States District Court sanctioned videoconference methodologies; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.and

Preliminary Approval. The Parties will 4.01 Within thirty (30) days after the execution of this Settlement Agreement, Class Counsel shall move the Court for an order certifying the Settlement Class and for a Preliminary Approval Order. The Preliminary Approval Order shall provide that the Court (a) preliminarily approves the terms and conditions of this Settlement Agreement as within the range of a fair, reasonable, and adequate settlement; (b) sets a date for a Court Approval Hearing; (c) approves the proposed Class Notice in the form attached hereto as Exhibit A and authorizes its dissemination to the Class pursuant to the terms of this Agreement; (d) approves the proposed Postcard Notice in the form attached hereto as Exhibit B and authorizes its dissemination to the Class pursuant to the terms of this Agreement; (f) sets deadlines consistent with this Agreement for distribution of the Class Notice, the publication of the Publication Notice, the filing of Objections, the filing of motions, the submission of Requests For Exclusion, the filing of an application by Class Counsel for fees and costs, the filing of an application by Class Counsel for a Service Payment to Plaintiff, and the filing of any other papers in connection with the Court Approval Hearing; (g) appoints and approves the Settlement Administrator; and (h) prohibits and preliminarily enjoins Plaintiff, all members of the Settlement Class (excepting those who submit Requests For Exclusion), and Class Counsel from commencing, prosecuting, or assisting in any lawsuit against the Released Persons that asserts or purports to assert matters within the scope of the Release during the time between entry of the Preliminary Approval Order in substantially and final determination by the form attached as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable Court regarding whether to grant final approval to the Settlement Class, and within the reasonable range of possible final approval; (b) certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Settlement. Class Counsel as counsel will share drafts of the motions for the Settlement Class for settlement purposes only; (c) approve the forms certification of Class Notice and find that the Notice Program constitutes the best notice practicable under the circumstances, provides due and sufficient notice to the Settlement Class and fully satisfies for the requirements of due process Preliminary Approval at least seven (7) days before filing these motions with the Court, and Federal Rule of Civil Procedure 23; (d) direct in the event that notice be provided Defendant has any objections to the Settlement Classmotions, Class Counsel and Defendant’s Counsel will meet and confer in accordance with this Agreement; (e) establish a procedure for Settlement Class Members an attempt to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approved, bar and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in resolve any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.objections.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not object to these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that, under Fed. R. Civ. P. 23(c)(2), the forms of Class Settlement Notice and find that the Notice Program constitutes the best notice practicable under the circumstances, provides due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and complies fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and any other applicable law; Cause the Settlement Administrator to send by first-class mail and/or e-mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper; Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) days after entry of the requirements Preliminary Approval Order, by any Former Participants, Beneficiaries, or Alternate Payees who do not have Active Accounts, who wish to receive the benefits of due process and Federal Rule of Civil Procedure 23this Settlement; (d) direct that notice be provided to the Settlement ClassProvide that, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred and forty (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14140) days after the Opt-Out and Objection Deadline and provide that this hearing maydate the motion for entry of the Preliminary Approval Order is filed, from time in order to time without further notice to determine whether: (a) the Court should approve the Settlement Classas fair, be continued or adjourned by order of reasonable, and adequate; (b) the CourtCourt should enter the Final Approval Order; and (lc) the Court should approve the Tolling Letters application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that any objections to any aspect of the Settlement Agreement shall be sent heard, and any papers submitted in support of said objections shall be considered, by the GEICO COMPANIES in response Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to notices Class Counsel and Defense Counsel. To be filed validly, the objection and any notice of intent to initiate litigation under Chapter 627 of the Florida Statutes participate or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on supporting documents must be filed or after the date of preliminary approval substantially in the form attached as Exhibit E.postmarked at least thirty

Preliminary Approval. The Parties will Promptly upon full execution of this Settlement Agreement, and no later than any applicable deadline set by the Court, Plaintiff shall move the Case 2:14-cv-01855-GW-GJS Document 112-1 Filed 12/27/19 Page 19 of 80 Page ID #:5813 Court for entry of the Preliminary Approval Order substantially in substantially the form attached as of Exhibit CA hereto for the purposes of, which shall specifically include provisions thatamong other things: (a) preliminarily approve approving the Settlement reflected memorialized in this Settlement Agreement as sufficiently fair, adequate and reasonable to such that Notice should be provided in accordance with the terms of this Settlement Class, and within the reasonable range of possible final approvalAgreement; (b) certify finding that the requirements for provisional certification of the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for the Settlement Class for settlement purposes onlyhave been satisfied; (c) approve certifying the forms Settlement Class as defined herein; (d) setting a date for a Final Approval Hearing; (e) approving the proposed Notice described in Section 4.2 herein, and directing its dissemination to Settlement Class Members in accordance with the terms of Class Notice and find this Settlement Agreement; (f) determining that the Notice Program constitutes of the best notice practicable under Settlement and of the circumstancesFinal Approval Hearing, provides due as set forth in this Settlement Agreement, complies with all legal requirements, including but not limited to the Due Process Clause of the United States Constitution; (g) providing that any objections by any Settlement Class Member to the proposed Settlement contained in this Settlement Agreement, the entry of the Final Order and sufficient notice Judgment, or to Settlement Class Counsel’s request for attorneys’ fees, costs, or service award, shall be heard and any papers submitted in support of said objections shall be considered by the Court at the Final Approval Hearing only if, on or before the date(s) specified in the Notice and Preliminary Approval Order, such objector submits to the Court a written objection, and otherwise complies with the requirements for objections set forth in Section 4.6 of this Settlement Agreement; (h) establishing dates by which Settlement Class Counsel shall file and serve all papers in support of final approval of the Settlement and in support of their application for attorneys’ fees, costs, and service award, and by which the Parties shall file and serve all papers in response to any objections; (i) providing that all Settlement Class Members will be bound by the Final Approval Order; (j) providing that persons within the Settlement Class definition wishing to exclude themselves from the Settlement Class will have until the date specified in the Notice and the Preliminary Approval Order to submit a valid written Request for Exclusion to the Settlement Administrator; (k) providing a procedure for persons in the Settlement Class to request exclusion from the Settlement Class; (l) directing the Parties, pursuant to the terms and fully satisfies conditions of this Settlement Agreement, to take all necessary and appropriate steps to establish the requirements means necessary to implement the Settlement; (m) setting deadlines consistent with this Settlement Agreement for dissemination of due process the Notice, requesting exclusion from the Settlement Class or objecting to the Settlement, and filing papers in connection with the Final Approval Hearing; (n) appointing the Settlement Class Representative and Settlement Class Counsel; (o) approving the appointment of the Settlement Administrator and the Calculation Advisor; and (p) enjoining the litigation or prosecution of all claims that will be released by the Settlement. For purposes of Settlement only, Bank of America will not oppose the Preliminary Approval Order or the certification, pursuant to Federal Rule of Civil Procedure 23; (d) direct that notice be provided to 23(b)(3), of the Settlement Class, in accordance with this Agreement; (e) establish a procedure for . Plaintiff and Settlement Class Members to object Counsel shall submit this Settlement Agreement to the Settlement or exclude themselves from the Settlement Class, Court and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approved, bar and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any request entry of the Released Claims against any Preliminary Approval Order. Entry of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation material terms of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as proposed Preliminary Approval Order set forth in Exhibit A is a material term of this Settlement Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E..

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable Exh bit C. Defendants will not object to these motions The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and comply fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and any other applicable law; Cause the Settlement Administrator to send by first class mail and/or e mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper thirty (30) calendar days after the entry of the Preliminary Approval Order Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) calendar days of entry of the requirements of due process and Federal Rule of Civil Procedure 23; (d) direct that notice be provided to the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement ClassPreliminary Approval by all Former Participants, and set Beneficiaries or Alternate Payees who do not have Active Accounts, who wish to receive the Opt-Out and Objection Deadlinebenefits of this Settlement; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) Provide that, pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred forty ( 40 calendar days after the date the otion for ntry of the Preliminary Approval Order is filed, in order to determine whether (a) the Court should approve the Settlement as fair, reasonable, and adequate; (hb) pending final determination t e Court should enter the Final Approval Order; and (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that any objections to any aspect of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any Settlement notice of intent to participate or supporting documents must be filed or postmarked at least thirty ( 0) calendar days prior tothe scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate fifteen calendar days (15) before the Fairness Hearing Provide that any party may file a response to an objection by a Class Member or any other Personat least (7) calendar days before the Fairness Hearing Provide that the Fairness Hearing may, without further direct notice to the Class Members, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement ClassClass Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will move As soon as reasonably possible and subject to any relevant Court Order, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not object to these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class as a non-opt out class for settlement purposes only under Fed. R. Civ. P. 23(b)(1); Approve the text of the Short Form Postcard Settlement Notice for mailing to Class Members and appoint Plaintiffs as class representatives and Class Counsel as counsel for the Long Form Settlement Notice to be posted on the Settlement Class for settlement purposes onlyWebsite; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice to of the Settlement Fairness Hearing and of the rights of all Class Members, and comply fully satisfies with the requirements of due process Fed. R. Civ. P. 23, the Constitution of the United States, and Federal Rule of Civil Procedure 23any other applicable law; (d) direct that notice be provided to Cause the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Administrator to send by first-class mail the Short Form Postcard Settlement Notice to each Class Members to object to Member identified by the Settlement or exclude themselves from Administrator based upon the Settlement Classdata provided by the Plan’s Recordkeeper; Provide that, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred twenty (120) calendar days after the date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether (a) the Court should approve the Settlement as fair, reasonable, and adequate; (hb) pending final determination the Court should enter the Final Order; and (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that any objections to any aspect of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any Settlement notice of intent to participate or supporting documents must be filed at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate within the time limitation set forth above; Provide that any party may file a response to an objection by a Class Member or any other PersonMember; and Provide that the Fairness Hearing may, without further direct notice to the Class Members, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement ClassClass Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E..

Preliminary Approval. The Parties will move As soon as reasonably possible and subject to any relevant Court Order, the Class Representatives, through Class Counsel, shall file with the Court a motion seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve C. Defendants will not object to the Settlement reflected relief sought in this Agreement motion even if they do not agree with all averments of the pleadings filed in support of Plaintiffs’ Motion for Preliminary Approval of Settlement, so long as sufficiently fair, adequate and reasonable they are consistent with the terms herein. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Modify the reasonable range definition of possible final approval; the certified class in the Order on Class Certification (bECF No. 124) certify to be the same as the definition of the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for defined in this Settlement Agreement; Approve the text of the Settlement Class for settlement purposes onlyNotices; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice to of the Settlement Fairness Hearing and of the rights of all Class Members, and comply fully satisfies with the requirements of due process Fed. R. Civ. P. 23, the Constitution of the United States, and Federal Rule of Civil Procedure 23any other applicable law; (d) direct that notice be provided to Cause the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Administrator to send by first-class mail the Short Form Postcard Settlement Notice to each Class Members to object to Member identified by the Settlement or exclude themselves from Administrator based upon the Settlement Classdata provided by the Plan’s Recordkeeper; Provide that, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than ninety (90) calendar days after the date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether (a) the Court should approve the Settlement as fair, reasonable, and adequate; (hb) pending final determination the Court should enter the Final Order; and (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that any objections to any aspect of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court. To be filed validly, the objection and any Settlement notice of intent to participate or supporting documents must be filed at least (14) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file with the Clerk of the Court a notice of intent to participate within the time limitation set forth above; Provide that any party may file a response to an objection by a Class Member or any other Personat least seven (7) calendar days before the Fairness Hearing; and Provide that the Fairness Hearing may, without further direct notice to the Class Members, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement ClassClass Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve the Tolling Letters to Court and/or be sent heard by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes Zoom or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.other United States District Court sanctioned videoconference methodologies.

Preliminary Approval. The Parties will 2.01 As soon as possible after the execution of this Agreement, and in no event later than _______________, 2007 (unless the date is extended by agreement or Court order), Class Counsel shall move the Court for entry of the Preliminary Approval Order an order substantially in substantially the form attached as of Exhibit C, which shall specifically include provisions that: D hereto (a) preliminarily approve approving the Settlement reflected memorialized in this Agreement as sufficiently fair, adequate reasonable and reasonable to adequate, including the Settlement Class, and within the reasonable range material terms of possible final approvalthis Agreement; (b) certify certifying the Settlement Class for settlement purposes only only, and appoint Plaintiffs as defined herein; (c) setting a date for a final approval hearing (“Fairness Hearing”); (d) approving the proposed Class Notice that is attached as Exhibit B, and authorizing its dissemination as set forth in the Agreement; (e) approving the proposed form of Publication Notice that is attached as Exhibit E, and authorizing its publication as set forth in this Agreement; (f) approving the requirement that Class Members file a claim form in order to obtain a Settlement Benefit, and the form of Claim Form attached as Exhibit A; (g) setting deadlines consistent with this Agreement for mailing of the Class Notices, publication of the Publication Notice, submission of Claim Forms, filing of objections, filing of motions to intervene, opting out of the Settlement, filing papers in connection with the Fairness Hearing, and the consideration of the approval or disapproval of the Settlement; (h) confirming the appointment of Xxxxx X. and Xxxxx X. XxXxxx and Xxxxx X. and Xxxxxxx X. Xxxxx as class representatives and Class Counsel as counsel for the Settlement Class for settlement purposes onlyClass; and (ci) 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 appointing the Settlement Class and fully satisfies Administrator. First Horizon will not oppose the requirements entry of due process and Federal Rule of Civil Procedure 23; (d) direct the Preliminary Approval order, provided that notice be provided to the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form it is substantially in the form attached as of Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approved, bar and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.D hereto.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not oppose these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Settlement Notice and find that the Notice Program constitutes the best notice practicable under the circumstances, provides due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and complies fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and other applicable law; Cause the Settlement Administrator to send by first-class mail and/or e-mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper; Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) days after entry of the requirements Preliminary Approval Order, by any Former Participants, Beneficiaries, or Alternate Payees who do not have Active Accounts, who wish to receive the benefits of due process and Federal Rule of Civil Procedure 23this Settlement; (d) direct that notice be provided to the Settlement ClassProvide that, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred and forty (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14140) days after the Opt-Out date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether: (a) the Court should approve the Settlement as fair, reasonable, and Objection Deadline adequate; (b) the Court should enter the Final Approval Order; and provide (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that this hearing any objections to any aspect of the Settlement Agreement shall be heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any notice of intent to participate or supporting documents must be filed or postmarked at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate fifteen days (15) before the Fairness Hearing; Provide that any party may file a response to an objection by a Class Member at least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, from time to time without further direct notice to the Settlement ClassClass Members, other than by notice to Class Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that, upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will After good-faith consultation with Counsel for Defendants, and within twenty (20) days after the execution of this Agreement, Class Counsel shall move the Court for entry of an order granting preliminary approval of this Agreement substantially in the form of Exhibit A hereto (the “Preliminary Approval Order in substantially the form attached as Exhibit COrder”), which order shall specifically include provisions that: (a) preliminarily approve the Settlement reflected settlement EXHIBIT 1 memorialized in this Agreement as sufficiently fair, adequate and reasonable to the Settlement Classreasonable, and within the reasonable range of possible final approvaladequate; (b) certify approve the Settlement proposed class notice in the form attached hereto as Exhibit B (the “Class for settlement purposes only Notice”), authorize its dissemination to the Class, and appoint Plaintiffs as class representatives and determine that such Class Counsel as counsel for Notice complies with all legal requirements, including, but not limited to, the Settlement Class for settlement purposes onlyDue Process Clause of the United States Constitution; (c) approve set a date for a final approval hearing (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 Settlement Class and fully satisfies the requirements of due process and Federal Rule of Civil Procedure 23“Final Approval Hearing”); (d) direct that notice be provided to the Settlement Class, in accordance set deadlines consistent with this AgreementAgreement for execution of Class Notice, the submissions of objections and opt-outs, and the filing of papers in connection with the Final Approval Hearing; (e) establish a procedure for require Settlement Class Members who wish to object exclude themselves to submit an appropriate and timely written request for exclusion by the deadline set pursuant to (d), as directed in the Settlement or exclude themselves Agreement and Class Notice, and advise that a failure to do so shall prevent those Settlement Class Members from doing so and shall bind those Settlement Class Members who remain in the Settlement Class, and set the Opt-Out and Objection Deadline; (f) appoint and approve the Claim Form substantially in the form attached Settlement Administrator (as Exhibit B and the claims process described in this Agreementdefined below); (g) pending final determination of whether authorize the Settling Parties to take all necessary and appropriate steps to establish the means necessary to implement the Settlement should be approved, bar Agreement; and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination issue related orders to effectuate the preliminary approval of whether the Settlement should be approvedAgreement. The Settling Parties shall, stay all proceedings in the Action except those related good faith, take reasonable steps to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed secure expeditious entry by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.Preliminary Approval Order.

Preliminary Approval. The Parties Promptly after the execution and delivery of this Agreement by all parties, provided that the Xxxxxx Case remains stayed, the Settlement Class Representatives will move the Court for entry of the Preliminary Approval Order in substantially the form attached as Exhibit COrder, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement herein as sufficiently fair, adequate and reasonable to the Settlement Class, and within the reasonable range of possible final approval; (b) conditionally certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for the Settlement Class for settlement purposes only; (c) approve the forms of New Class Notice and find that the Notice Program notice program set forth herein constitutes the best notice practicable under the circumstances, provides due and sufficient notice to the Settlement Class and fully satisfies the requirements of due process and Federal Rule of Civil Procedure 23; (d) direct that notice New Class Notice be provided to the Settlement Class, in accordance with this Agreement, within forty-five (45) days following receipt of the entered Preliminary Approval Order by NCG’s counsel (the “Notice Deadline”); (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set a date sixty (60) days after the Opt-Notice Deadline, after which no one shall be allowed to object to the Settlement or exclude himself or herself from the Settlement Class or seek to intervene in the Action (the “Opt Out and Objection Deadline”); (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims payment process described in this Agreementherein; (g) pending final determination approval of whether the Settlement should be approvedSettlement, bar and preliminarily enjoin all Settlement Class Members, directlydirectly or indirectly, on a representative basis basis, or in any other capacity, capacity from commencing, prosecuting, intervening in, commencing or participating as a plaintiff or class member in prosecuting against any of the Released Parties any action, arbitration, arbitration or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released PartiesClaims; (h) pending final determination approval of whether the Settlement should be approvedSettlement, stay all proceedings in the Action Xxxxx Case except those related to the effectuation of the Settlement; and (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval final approval of the Settlement, which shall be scheduled no earlier than fourteen forty-five (1445) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.Deadline.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court a motion seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in C. Defendants will not oppose this Agreement as sufficiently fair, adequate and reasonable motion. The Preliminary Approval Order to be presented to the Court shall, among other things: Approve the selection of Settlement Class, Administrator and within Escrow Agent; Grant the reasonable range motion to maintain certification of possible final approval; (b) certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice (including the Former Participant Claim Form) for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice Settlement Notices and find that the Notice Program constitutes Former Participant Claim Form constitute the best notice practicable under the circumstances, provides provide due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and comply fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and any other applicable law; Cause the Settlement Administrator to send by first-class mail and/or e-mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper; Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) days after entry of the requirements Preliminary Approval Order, by any Former Participants, Beneficiaries, or Alternate Payees who do not have Active Accounts, who wish to receive the benefits of due process and Federal Rule of Civil Procedure 23this Settlement; (d) direct that notice be provided to the Settlement ClassProvide that, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on through a representative basis Representative, or in any other capacity, from commencing, prosecuting, intervening in, commence or participating as a plaintiff or class member in prosecute any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred and forty (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14140) days after the Opt-Out date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether: (a) the Court should approve the Settlement as fair, reasonable, and Objection Deadline adequate; (b) the Court should enter the Final Approval Order; and provide (c) the Court should approve the application for Attorneys’ Fees and Litigation Expenses, Class Representatives’ Case Contribution Award, and Administrative Expenses; Provide that this hearing any objections to any aspect of the Settlement Agreement shall be heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any notice of intent to participate or supporting documents must be filed or postmarked at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate fifteen days (15) before the Fairness Hearing; Provide that any party may file a response to an objection by a Class Member at least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, from time to time without further direct notice to the Settlement ClassClass Members, other than by notice to Class Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representative, through Class Counsel, shall file with the Court a motion seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in C. Defendants will not oppose this Agreement as sufficiently fair, adequate and reasonable motion. The Preliminary Approval Order to be presented to the Court shall, among other things: Approve the selection of Settlement Class, Administrator and within Escrow Agent; Grant the reasonable range motion to maintain certification of possible final approval; (b) certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice (including the Former Participant Claim Form) for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice Settlement Notices and find that the Notice Program constitutes Former Participant Claim Form constitute the best notice practicable under the circumstances, provides provide due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and comply fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and any other applicable law; Cause the Settlement Administrator to send by first-class mail and/or e-mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper; Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) days after entry of the requirements Preliminary Approval Order, by any Former Participants, Beneficiaries, or Alternate Payees who do not have Active Accounts, who wish to receive the benefits of due process and Federal Rule of Civil Procedure 23this Settlement; (d) direct that notice be provided to the Settlement ClassProvide that, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on through a representative basis Representative, or in any other capacity, from commencing, prosecuting, intervening in, commence or participating as a plaintiff or class member in prosecute any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred and forty (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14140) days after the Opt-Out date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether: (a) the Court should approve the Settlement as fair, reasonable, and Objection Deadline adequate; (b) the Court should enter the Final Approval Order; and provide (c) the Court should approve the application for Attorneys’ Fees and Litigation Expenses, Class Representative’s Case Contribution Award, and Administrative Expenses; Provide that this hearing any objections to any aspect of the Settlement Agreement shall be heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any notice of intent to participate or supporting documents must be filed or postmarked at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate fifteen days (15) before the Fairness Hearing; Provide that any party may file a response to an objection by a Class Member at least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, from time to time without further direct notice to the Settlement ClassClass Members, other than by notice to Class Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will move Promptly upon full execution of this Settlement Agreement, Plaintiffs shall move, or otherwise request that, the Court for entry of the Preliminary Approval Order substantially in substantially the form attached as of Exhibit CJ to this Settlement Agreement, which shall specifically include provisions thatfor the purposes of, among other things: (a) preliminarily approve approving the Settlement reflected settlement memorialized in this Settlement Agreement as sufficiently fair, adequate and reasonable to such that Notice should be provided in accordance with the terms of this Settlement Class, and within the reasonable range of possible final approvalAgreement; (b) certify finding that the requirements for provisional certification of the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for the Settlement Class for settlement purposes onlyhave been satisfied; (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 certifying the Settlement Class and fully satisfies the requirements of due process and Federal Rule of Civil Procedure 23as defined herein; (d) direct that notice be provided to the Settlement Class, in accordance with this Agreementsetting a date for a Fairness Hearing; (e) establish a procedure for approving the proposed Notice program described in Section VI herein (including the proposed forms and methods of notice), and directing its dissemination to Settlement Class Members to object to in accordance with the terms of this Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection DeadlineAgreement; (f) approve determining that the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approvedNotice program, bar and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Settlement Agreement, complies with all legal requirements, including but not limited to the Due Process Clause of the United States Constitution; (g) approving the proposed Claim Form and Claims Process, and directing that the Claim Process be implemented pursuant to the terms of this Settlement Agreement; (jh) provide providing that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted any objections by any Settlement Class Member to this Settlement Agreement, the entry of the Final Order and Judgment, or to Settlement Class Counsel’s request for attorneys’ fees, costs, or service awards, shall be heard and any other Person, other than as may papers submitted in support of said objections shall be directed considered by the Court upon at the Fairness Hearing only if, on or before the date(s) specified in the Notice and Preliminary Approval Order, such objector submits to the Court a proper showing seeking such discovery by motion properly filed with this Courtwritten objection, noticed and served in accordance otherwise complies with the governing rules requirements for objections set forth in Section VIII of procedurethis Settlement Agreement; (i) establishing dates by which Settlement Class Counsel shall file and serve all papers in support of final approval of the Settlement and in support of their application for attorneys’ fees, costs, and service awards, and by which the Parties shall file and serve all papers in response to any objections; (j) providing that all Settlement Class Members who do not submit timely and valid requests for exclusion will be bound by the Final Order and Judgment; (k) schedule providing a hearing on Final Approval procedure for persons in the Settlement Class to request exclusion from the Settlement Class; (l) directing the Parties, pursuant to the terms and conditions of this Settlement Agreement, to take all necessary and appropriate steps to establish the means necessary to implement the Settlement; (m) setting deadlines consistent with this Settlement Agreement for dissemination of Notice, requesting exclusion from the Settlement Class or objecting to the Settlement, which shall be scheduled no earlier than fourteen (14) days after and filing papers in connection with the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.Fairness Hearing;

Preliminary Approval. The Parties will Promptly upon full execution of this Settlement Agreement, Plaintiffs shall move the Court for entry of the Preliminary Approval Order substantially in substantially the form attached as of Exhibit CH to this Settlement Agreement, which shall specifically include provisions thatfor the purposes of, among other things: (a1) preliminarily approve approving the Settlement reflected settlement memorialized in this Settlement Agreement as sufficiently fair, adequate and reasonable to such that Notice should be provided in accordance with the terms of this Settlement Class, and within the reasonable range of possible final approvalAgreement; (b2) certify finding that the requirements for provisional certification of the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for have been satisfied; (3) certifying the Settlement Class for settlement purposes onlyas defined herein; (c4) approve setting a date for a Fairness Hearing; (5) approving the proposed Notice program described in Section VI herein (including the proposed forms and methods of Class notice), and directing dissemination of Notice and find that the Notice Program constitutes the best notice practicable under the circumstances, provides due and sufficient notice to the 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 Settlement Class, in accordance with the terms of this Settlement Agreement; (e6) establish a procedure for Settlement Class Members to object to determining that the Settlement or exclude themselves from the Settlement ClassNotice program, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approved, bar and preliminarily enjoin all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Settlement Agreement, complies with all legal requirements, including but not limited to the Due Process Clause of the United States Constitution; (7) approving the proposed Claim Form and Claims Process, and directing that the Claim Process be implemented pursuant to the terms of this Settlement Agreement; (j) provide 8) providing that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted any objections by any Settlement Class Member to this Settlement Agreement, the entry of the Final Order and Judgment, or to Settlement Class Counsel’s request for attorneys’ fees, costs, or service awards, shall be heard and any other Person, other than as may papers submitted in support of said objections shall be directed considered by the Court upon at the Fairness Hearing only if, on or before the date(s) specified in the Notice and Preliminary Approval Order, such objector submits to the Court a proper showing seeking such discovery written objection, and otherwise complies with the requirements for objections set forth in Section VIII of this Settlement Agreement; (9) establishing dates by motion properly filed which Settlement Class Counsel shall file and serve all papers in support of final approval of the Settlement and in support of their application for attorneys’ fees, costs, and service awards, and by which the Parties shall file and serve all papers in response to any objections; (10) providing that all Settlement Class Members who do not submit timely and valid requests for exclusion will be bound by the Final Order and Judgment; (11) providing a procedure for persons in the Settlement Class to request exclusion from the Settlement Class; (12) directing the Parties, pursuant to the terms and conditions of this Settlement Agreement, to take all necessary and appropriate steps to establish the means necessary to implement the Settlement; (13) setting deadlines consistent with this CourtSettlement Agreement for dissemination of Notice, noticed and served in accordance with requesting exclusion from the governing rules of procedure; (k) schedule a hearing on Final Approval of Settlement Class or objecting to the Settlement, which shall be scheduled no earlier than fourteen and filing papers in connection with the Fairness Hearing; (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to appointing the Settlement Class, be continued or adjourned by order Class Representatives and Settlement Class Counsel; (15) approving the appointment of the CourtSettlement Administrator; and (l16) approve enjoining the Tolling Letters to litigation or prosecution of all claims that will be sent released by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.Settlement.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not oppose these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range motion to maintain certification of possible final approval; (b) certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and comply fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and any other applicable law; Cause the Settlement Administrator to send by first-class mail and/or e-mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper; Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) days after entry of the requirements Preliminary Approval Order, by any Former Participants, Beneficiaries, or Alternate Payees who do not have Active Accounts, who wish to receive the benefits of due process and Federal Rule of Civil Procedure 23this Settlement; (d) direct that notice be provided to the Settlement ClassProvide that, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred and forty (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14140) days after the Opt-Out date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether: (a) the Court should approve the Settlement as fair, reasonable, and Objection Deadline adequate; (b) the Court should enter the Final Approval Order; and provide (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that this hearing any objections to any aspect of the Settlement Agreement shall be heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any notice of intent to participate or supporting documents must be filed or postmarked at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate fifteen days (15) before the Fairness Hearing; Provide that any party may file a response to an objection by a Class Member at least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, from time to time without further direct notice to the Settlement ClassClass Members, other than by notice to Class Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not take a position on these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and comply fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and any other applicable law; Cause the Settlement Administrator to send by first-class mail and/or e-mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper; Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) days after entry of the requirements Preliminary Approval Order, by any Former Participants, Beneficiaries, or Alternate Payees who do not have Active Accounts, who wish to receive the benefits of due process and Federal Rule of Civil Procedure 23this Settlement; (d) direct that notice be provided to the Settlement ClassProvide that, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred and forty (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14140) days after the Opt-Out date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether: (a) the Court should approve the Settlement as fair, reasonable, and Objection Deadline adequate; (b) the Court should enter the Final Approval Order; and provide (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that this hearing any objections to any aspect of the Settlement Agreement shall be heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any notice of intent to participate or supporting documents must be filed or postmarked at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate fifteen days (15) before the Fairness Hearing; Provide that any party may file a response to an objection by a Class Member at least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, from time to time without further direct notice to the Settlement ClassClass Members, other than by notice to Class Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will move Within a reasonable time after execution of this Settlement Agreement by the Parties, Plaintiff shall apply to the Court for the entry of the Preliminary Approval Order in substantially the form attached as Exhibit C, which shall specifically include provisions thatan Order: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable to the Settlement Class, and within the reasonable range of possible final approval; (b) certify Conditionally certifying the Settlement Class for settlement purposes only of this Settlement Agreement; Appointing Xxxx X. Xxxxxx of Xxxxxx Law Group, APC and appoint Plaintiffs Xxxxx X. Xxxxxx, Xxxxx Xxxxx, Xxxxxxxxx Xxxxxx, and Romina Tamiry of Xxxxxx Law, APC as class representatives and Class Counsel Counsel; Appointing Xxxxxxxxx Xxxxxxxx as counsel Class Representative for the Settlement Class for settlement purposes onlyClass; Approving Phoenix Settlement Administrators as Settlement Administrator; Preliminarily approving this Settlement Agreement and its terms as fair, reasonable, and adequate; Approving the form and content of the Notice Packet (c) approve which is comprised of the forms Notice of Pendency of Class Action and Settlement and Notice and find that the Notice Program constitutes the best notice practicable under the circumstancesof Individual Settlement Award, provides due and sufficient notice to the Settlement Class and fully satisfies the requirements drafts of due process and Federal Rule of Civil Procedure 23; (d) direct that notice be provided to the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Classwhich are attached collectively hereto as Exhibit A), and set directing the Opt-Out and Objection Deadlinemailing of same; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement should be approved, bar and preliminarily enjoin Staying all Settlement Class Members, directly, on a representative basis or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in any action, arbitration, or proceeding in any court, arbitration forum or tribunal asserting any of the Released Claims against any of the Released Parties; (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of until Final Approval; and Scheduling a Final Approval hearing. The Preliminary Approval Order shall be substantially the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks same as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form attached as Exhibit E.C. Class Counsel must draft the preliminary approval papers and give Defendants’ counsel a draft of the papers to review at least five (5) calendar days before the filing deadline. Defendants shall be permitted, but not required, to file their own brief or statement in support of Preliminary Approval. Defendants agree not to file an opposition to the Motion for Preliminary Approval or Motion for Final Approval.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not object to these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice to of the Settlement Fairness Hearing and of the rights of all Class Members, and comply fully satisfies with the requirements of due process Fed. R. Civ. P. 23, the Constitution of the United States, and Federal Rule of Civil Procedure 23any other applicable law; (d) direct that notice be provided to Cause the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members Administrator to object to send by first-class mail the Settlement or exclude themselves from Notice to each Class Member identified by the Settlement ClassAdministrator based upon the data provided by the Plan’s Recordkeeper; Provide that, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred twenty (120) calendar days after the date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether (a) the Court should approve the Settlement as fair, reasonable, and adequate; (hb) pending final determination the Court should enter the Final Order; and (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that any objections to any aspect of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any Settlement notice of intent to participate or supporting documents must be filed at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate within the time limitation set forth above; Provide that any party may file a response to an objection by a Class Member or any other Personat least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, without further direct notice to the Class Members, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement ClassClass Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will move As soon as reasonably possible upon the full execution of this Settlement Agreement by the Settling Parties, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not object to these motions. The Preliminary Approval Order to be presented to the Settlement ClassCourt shall, and within among other things: Grant the reasonable range of possible final approval; (b) motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing or sending by electronic means to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice of the Fairness Hearing and of the rights of all Class Members, and comply fully with the requirements of Fed. R. Civ. P. 23, the Constitution of the United States, and any other applicable law; Cause the Settlement Administrator to send by first-class mail and/or e- mail the Settlement Notice and Former Participant Claim Form to each Class Member identified by the Settlement Administrator based upon the data provided by the Plan’s Recordkeeper; Provide that the Former Participant Claim Form must be returned to the Settlement Class Administrator within one hundred and fully satisfies twenty (120) days after entry of the requirements Preliminary Approval Order, by any Former Participants, Beneficiaries, or Alternate Payees who do not have Active Accounts, who wish to receive the benefits of due process and Federal Rule of Civil Procedure 23this Settlement; (d) direct that notice be provided to the Settlement ClassProvide that, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred and forty (h) pending final determination of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other Person, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14140) days after the Opt-Out date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether: (a) the Court should approve the Settlement as fair, reasonable, and Objection Deadline adequate; (b) the Court should enter the Final Approval Order; and provide (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that this hearing any objections to any aspect of the Settlement Agreement shall be heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any notice of intent to participate or supporting documents must be filed or postmarked at least thirty (30) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate fifteen days (15) before the Fairness Hearing; Provide that any party may file a response to an objection by a Class Member at least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, from time to time without further direct notice to the Settlement ClassClass Members, other than by notice to Class Counsel, be adjourned or continued or adjourned by order of the Court; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.

Preliminary Approval. The Parties will 2.01 This Settlement Agreement must be fully executed on or before January 4, 2022, so that, before the Case Management Conference with Judge Xxxxxx on January 12, 2022, Plaintiff’s Counsel can move the Court to enter an order for entry of the Preliminary Approval Order substantially in substantially the form attached as of Exhibit CA hereto (“Preliminary Approval Order”), which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected memorialized in this Settlement Agreement as sufficiently fair, adequate reasonable, and reasonable to adequate; (b) provisionally approve the Settlement Class, and within the reasonable range of possible final approval; (b) certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for the Settlement Class for settlement purposes only; (c) conditionally designate Representative Plaintiff as the representative of the Settlement Class and Plaintiff’s Counsel as counsel for the Settlement Class; (d) set a date for a final approval hearing (“Court Approval Hearing”); (e) approve the forms of proposed Class Notice attached hereto as Exhibit B and find that the Notice Program constitutes the best notice practicable under the circumstances, provides due and sufficient notice authorize its dissemination to the 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 Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members to object to the Settlement or exclude themselves from the Settlement Class, and set the Opt-Out and Objection Deadlinemembers; (f) approve continue the Claim Form substantially stay of all proceedings and deadlines in the form attached as Exhibit B and Action, which are not related to effectuating the claims process described in this AgreementSettlement, until the Final Approval hearing; (g) pending final determination of whether set deadlines consistent with this Agreement for emailing the Settlement should be approvedClass Notice, bar filing objections, filing motions, and filing papers required for the Final Approval hearing; and (h) prohibit and preliminarily enjoin Representative Plaintiff, all Settlement Class Members, directlyClass Counsel, on a representative basis or in any other capacity, and Plaintiff’s Counsel from commencing, prosecuting, intervening in, or participating as a plaintiff or class member assisting in any action, arbitration, lawsuit against the Released Persons that asserts or proceeding in any court, arbitration forum or tribunal asserting any purports to assert matters within the scope of the Released Claims against any Release during the time between entry of the Released Parties; (h) pending final determination of whether Preliminary Approval Order and the Settlement should be approved, stay all proceedings in Court’s decision on the Action except those related request for Final Approval. Defendants agree not to effectuation oppose the request the entry of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted by any Settlement Class Member or any other PersonPreliminary Approval Order, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement Class, be continued or adjourned by order of the Court; and (l) approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval provided it is substantially in the form of Exhibit A attached as Exhibit E.hereto.

Preliminary Approval. The Parties will move As soon as reasonably possible and subject to any relevant Court Order, the Class Representatives, through Class Counsel, shall file with the Court motions seeking preliminary approval of this Settlement Agreement and for entry of the Preliminary Approval Order in substantially the form attached hereto as Exhibit C, which shall specifically include provisions that: (a) preliminarily approve the Settlement reflected in this Agreement as sufficiently fair, adequate and reasonable C. Defendants will not object to the Settlement Classrelief sought in these motions even if they do not agree with all averments of the pleadings filed in support of Plaintiffs’ Motion for Preliminary Approval of Settlement, and within so long as they are consistent with the reasonable range of possible final approval; (b) terms herein. The Preliminary Approval Order to be presented to the Court shall, among other things: Grant the motion to certify the Settlement Class for settlement purposes only and appoint Plaintiffs as class representatives and Class Counsel as counsel for under Fed. R. Civ. P. 23(b)(1); Approve the text of the Settlement Notice for mailing to Class for settlement purposes onlyMembers; (c) approve Determine that under Fed. R. Civ. P. 23(c)(2), the forms of Class Notice and find that the Notice Program constitutes Settlement Notices constitute the best notice practicable under the circumstances, provides provide due and sufficient notice to of the Settlement Fairness Hearing and of the rights of all Class Members, and comply fully satisfies with the requirements of due process Fed. R. Civ. P. 23, the Constitution of the United States, and Federal Rule of Civil Procedure 23any other applicable law; (d) direct that notice be provided to Cause the Settlement Class, in accordance with this Agreement; (e) establish a procedure for Settlement Class Members Administrator to object to send by first-class mail the Settlement or exclude themselves from Notice to each Class Member identified by the Settlement ClassAdministrator based upon the data provided by the Plan’s Recordkeeper; Provide that, and set the Opt-Out and Objection Deadline; (f) approve the Claim Form substantially in the form attached as Exhibit B and the claims process described in this Agreement; (g) pending final determination of whether the Settlement Agreement should be approved, bar and preliminarily enjoin all Settlement no Class Members, Member may directly, on a representative basis through Representatives, or in any other capacity, from commencing, prosecuting, intervening in, or participating as a plaintiff or class member in commence any action, arbitration, action or proceeding in any court, arbitration forum court or tribunal asserting any of the Released Claims against any of Defendants, the Released Parties, and/or the Plan; Set the Fairness Hearing for no sooner than one hundred twenty (120) calendar days after the date the motion for entry of the Preliminary Approval Order is filed, in order to determine whether (a) the Court should approve the Settlement as fair, reasonable, and adequate; (hb) pending final determination the Court should enter the Final Order; and (c) the Court should approve the application for Attorneys’ Fees and Costs, Class Representatives’ Case Contribution Awards, Administrative Expenses incurred to date, and a reserve for anticipated future Administrative Expenses; Provide that any objections to any aspect of whether the Settlement should be approved, stay all proceedings in the Action except those related to effectuation of the Settlement; (i) approve and appoint a Claims Administrator to perform the tasks as set forth in this Agreement; (j) provide that no discovery (except for reasonable confirmatory discovery requested by Class Counsel) with regard to the Settlement Agreement or the proposed Settlement and its administration shall be permitted heard, and any papers submitted in support of said objections shall be considered, by the Court at the Fairness Hearing if they have been filed validly with the Clerk of the Court and copies provided to Class Counsel and Defense Counsel. To be filed validly, the objection and any Settlement notice of intent to participate or supporting documents must be filed at least (14) calendar days prior to the scheduled Fairness Hearing. Any Person wishing to speak at the Fairness Hearing shall file and serve a notice of intent to participate within the time limitation set forth above; Provide that any party may file a response to an objection by a Class Member or any other Personat least seven (7) calendar days before the Fairness Hearing; Provide that the Fairness Hearing may, without further direct notice to the Class Members, other than as may be directed by the Court upon a proper showing seeking such discovery by motion properly filed with this Court, noticed and served in accordance with the governing rules of procedure; (k) schedule a hearing on Final Approval of the Settlement, which shall be scheduled no earlier than fourteen (14) days after the Opt-Out and Objection Deadline and provide that this hearing may, from time to time without further notice to the Settlement ClassClass Counsel, be adjourned or continued or adjourned by order of the CourtCourt and/or be heard by Zoom or other United States District Court sanctioned videoconference methodologies; and (l) approve Approve the Tolling Letters to be sent by the GEICO COMPANIES in response to notices of intent to initiate litigation under Chapter 627 form of the Florida Statutes or civil remedies notices under Chapter 624 of the Florida Statutes received from Settlement Class Members on or after the date of preliminary approval substantially in the form CAFA Notice attached as Exhibit E.E and order that upon mailing of the CAFA Notices, Defendants shall have fulfilled their obligations under CAFA.