Preliminary Settlement Hearing. Upon execution of this Agreement by all Parties, Plaintiff will move the Court, unopposed by Defendant, for the entry of a Preliminary Approval Order. The proposed Preliminary Approval Order that will be attached to the motion shall be in a form agreed upon by Class Counsel and Navy Federal’s counsel. The motion for preliminary approval shall, among other things, request that the Court: (i) approve the terms of the Settlement as within the range of fair, adequate, and reasonable; (ii) provisionally certify the Settlement Class for settlement purposes only; (iii) approve the Class Notice and procedures set forth below; (iv) approve the procedures for Class Members to exclude themselves from the Settlement Class or to object to the Settlement; (v) stay the Action pending Final Approval of the Settlement; and (iv) if necessary, schedule a Final Approval Hearing.
Preliminary Settlement Hearing. Within seven (7) days of execution of this Agreement, the Settling Parties will jointly move the Court for the entry of a Preliminary Approval Order. In conjunction with the Preliminary Approval hearing, Class Counsel will submit this Agreement, which sets forth the terms of this Settlement, and will include proposed forms of all notices and other documents as attached hereto necessary to implement the Settlement.
Preliminary Settlement Hearing. Plaintiff will move the Court, unopposed by Defendants, for the entry of a Preliminary Approval Order and for approval of proposed forms of all notices and other documents necessary to implement the Settlement.
