Common use of Procedure for Approving Settlement Clause in Contracts

Procedure for Approving Settlement. a. Plaintiff will file an unopposed motion for an order conditionally certifying the Class, giving Preliminary Approval to the Settlement, setting a date for the Final Approval Hearing, and approving the Notice (the “Unopposed Motion for Preliminary Approval”). b. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval of the Settlement Agreement; appointing the Class Representative and Class Counsel; approving the Notice to the Class of the Settlement; and setting the Final Approval Hearing. c. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representative, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counsel. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the Court, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff (a) Within seven days after execution of this Settlement Agreement, Plaintiffs will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to granting preliminary approval of the Settlement, appointing Plaintiffs as Class Representatives, appointing Plaintiffs’ Counsel as Class Counsel, setting a date for the Final Approval Hearing, and approving the form and method of issuing the Settlement Notice (the “Unopposed Motion for Preliminary Approval”). b. (b) At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Settlement Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative Representatives and Class Counsel; approving the Settlement Notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. (c) For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Settlement Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff Plaintiffs shall be conditionally appointed Class RepresentativeRepresentatives, and that Plaintiff’s Plaintiffs’ Counsel shall be conditionally appointed as Class Counsel. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the Court, the Settlement Agreement will be null and void, and the Parties will have no further obligations under itthe Settlement Agreement, and the Parties will revert to their prior positions in the Action Litigation as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiff will file an unopposed a motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form, and should Defendant not have any substantive objections thereto, provide for the Court to review and approve the relief requested therein (the “Unopposed Motion for Preliminary Approval”)) under the terms specified herein. b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice Claim Form and the forms of notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representativeclass representative, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiff will file an unopposed motion for an order conditionally certifying the Class, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Notice Class Notice, and Claim Form (the “Unopposed Motion for Preliminary Approval”). b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice Claim Form and the forms of notice to the Class of the Settlement; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representativeclass representative for the Class, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff Counter-Plaintiffs will file an unopposed the Parties’ joint motion for an order conditionally certifying the Class, giving Preliminary Approval to the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”). b. At the hearing on the Unopposed Joint Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement Agreement; appointing the Class Representative Representatives and Class Counsel; approving the forms of Notice to the Class of the Settlement; and setting the Final Approval Hearing. c. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff Counter-Plaintiffs shall be conditionally appointed Class RepresentativeRepresentatives, and that Plaintiff’s Counter-Plaintiffs’ Counsel shall be conditionally appointed as Class Counsel. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approvalpreliminary approval. If and only if the Parties are unable to obtain Preliminary Approval preliminary approval of a settlement agreement after submitting at least two renegotiated settlements to the Court, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action Consolidated Actions as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiffs will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”)) under the terms specified herein. b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative Representatives and Class Counsel; approving the Notice Claim Form and the forms of notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff Plaintiffs shall be conditionally appointed Class Representativeclass representatives for the Class, and that Plaintiff’s Plaintiffs’ Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff Counter-Plaintiffs will file an unopposed the Parties’ joint motion for an order conditionally certifying the Class, giving Preliminary Approval to the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Faun (the “Joint/Unopposed Motion for Preliminary Approval”). b. At the hearing on the Unopposed Joint Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Joint/Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement Agreement; appointing the Class Representative Representatives and Class Counsel; approving the forms of Notice to the Class of the Settlement; and setting the Final Approval Hearing. c. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Settlement Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff Counter-Plaintiffs shall be conditionally appointed Class RepresentativeRepresentatives, and that Plaintiff’s Counter-Plaintiffs’ Counsel shall be conditionally appointed as Class Counsel. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approvalpreliminary approval. If and only if the Parties are unable to obtain Preliminary Approval preliminary approval of a settlement agreement after submitting at least two renegotiated settlements to the Court, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action Consolidated Actions as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement i. Plaintiff will file an unopposed motion for an order conditionally certifying the Class, appointing Plaintiff’s counsel as Class Counsel, appointing Plaintiff as Class Representative, appointing JND as Settlement Administrator, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Notice and directing its dissemination by the Settlement Administrator (the “Unopposed Motion for Preliminary Approval”). b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice form of notice to the Class of the Settlement; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Settlement Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class RepresentativeRepresentative for the Class, and that Plaintiff’s Counsel counsel shall be conditionally appointed as Class CounselCounsel for the Settlement Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions the status quo ex ante in the Action Litigation as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiff will file an unopposed motion for an order conditionally certifying the Settlement Class, ordering a response to the Class List Subpoena described in Section X, giving Preliminary Approval to the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”)) under the terms specified herein. b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; ordering Defendant to comply with the Class List Subpoena by 30 days from the date of the Order; approving the Notice Claim Form and the forms of notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representativeclass representative, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff Plaintiffs will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”). b. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative Representatives and Class Counsel; approving the Claim Form and the forms of Notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff Plaintiffs shall be conditionally appointed Class RepresentativeRepresentatives, and that Plaintiff’s Plaintiffs’ Counsel shall be conditionally appointed as Class Counsel. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the Court, the Settlement Agreement will be null and void, and the Parties will have no further obligations under itthe Agreement, and the Parties will revert to their prior positions in the Action Litigation as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiffs will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”)) under the terms specified herein. b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative Representatives and Class Counsel; approving the Notice Claim Form and the forms of notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff Plaintiffs shall be conditionally appointed Class Representativeclass representatives, and that Plaintiff’s Plaintiffs’ Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action Litigation as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiff will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”). b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice Claim Form and the forms of notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representativelass representative for the Class, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement i. Plaintiff will file an unopposed motion for an order conditionally certifying the Settlement Class, appointing Plaintiff’s counsel as Class Counsel, appointing Plaintiff as Class Representative, appointing JND as Settlement Administrator, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Notice and directing its dissemination by the Settlement Administrator (the “Unopposed Motion for Preliminary Approval”). b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Settlement Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice form of notice to the Settlement Class of the Settlement; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Settlement Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class RepresentativeRepresentative for the Class, and that Plaintiff’s Counsel counsel shall be conditionally appointed as Class CounselCounsel for the Settlement Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions the status quo ex ante in the Action Litigation as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff will file an unopposed motion for an order conditionally certifying the Class, giving Preliminary Approval to the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”). b. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement Agreement; appointing the Class Representative and Class Counsel; approving the Claim Form and the forms of Notice to the Class of the Settlement; and setting the Final Approval Hearing. c. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representative, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counsel. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approvalpreliminary approval. If and only if the Parties are unable to obtain Preliminary Approval preliminary approval of a settlement agreement after submitting at least two renegotiated settlements to the Court, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action Litigation as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff A. Amending the Complaint. Prior to filing Plaintiffs’ Motion for Preliminary Approval or at the time preliminary approval is sought, Plaintiffs will file an unopposed motion the First Amended Complaint in the Class Action. B. Motion for Preliminary Approval and Conditional Certification. i. Plaintiffs will move for an order order: (1) conditionally certifying the Class, giving Class for settlement purposes only; (2) granting Preliminary Approval to of the Settlement, ; (3) setting a date for the Final Approval Hearing, hearing; (4) and approving the Notice (the “Unopposed Motion for Preliminary Approval”)Class Notice. b. ii. At the hearing on the Unopposed same time that Plaintiffs files their Motion for Preliminary Approval, Plaintiffs shall send a copy of the Parties Agreement to the LWDA pursuant to the 2016 amendments to PAGA. iii. At the Preliminary Approval hearing, Plaintiffs will jointly appear, support the granting of the Unopposed Motion for Preliminary Approvalmotion, and submit a proposed order granting conditional certification of the Class and Preliminary Approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice to the Class Representatives, iv. Effect of the Settlement; and setting the Final Approval Hearing. c. For the purposes Denial of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representative, and that Plaintiff’s Counsel shall be conditionally appointed as Class CounselPreliminary Approval. Should the Court decline to enter conditionally certify the Preliminary Approval Order Class or otherwise decline to preliminarily approve any aspect of the Settlement Agreement, the Parties will attempt to renegotiate those Preliminarily Approve all material aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it. Provided, however, that the amounts of the Attorneys Fee Award, Cost Award, Administration Costs, and Class Representative Enhancement Payments shall be determined by the Court, and the Parties will revert Court’s determination on these amounts shall be final and binding, and that the Court’s approval or denial of any amount requested for these items are not conditions of this Settlement Agreement, and are to their prior positions in be considered separate and apart from the Action as if fairness, reasonableness, and adequacy of the Settlement had Agreement. Any order or proceeding relating to an application for the Attorneys Fee Award, Cost Award, Administration Costs, and Class Representative Enhancement Payments shall not occurredoperate to terminate or cancel this Settlement Agreement. Nothing in this Agreement shall limit Plaintiffs’ or Class Counsel’s ability to appeal any decision by the Court to award less than the requested Attorneys Fee Award, Cost Award, Administration Costs, and Class Representative Enhancement Payments.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement i. Plaintiff will file an unopposed motion for an order conditionally certifying the Class, appointing Plaintiff’s counsel as Class Counsel, appointing Plaintiff as Class Representative, appointing JND Settlement Administrator as Settlement Administrator, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Notice and directing its dissemination by the Settlement Administrator (the “Unopposed Motion for Preliminary Approval”). b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice form of notice to the Class of the Settlement; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Settlement Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class RepresentativeRepresentative for the Class, and that Plaintiff’s Counsel counsel shall be conditionally appointed as Class CounselCounsel for the Settlement Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions the status quo ex ante in the Action Litigation as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiff will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”)) under the terms specified herein. b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval FILED DATE: 11/26/2019 1:08 PM 2018CH05903 preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice Claim Form and the forms of notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representativeclass representative for the Class, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred.

Procedure for Approving Settlement. a. Plaintiff will file an unopposed the Parties’ joint motion for an order conditionally certifying the Class, giving Preliminary Approval to the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”). b. At the hearing on the Unopposed Joint Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement Agreement; appointing the Class Representative and Class Counsel; approving the forms of Notice to the Class of the Settlement; and setting the Final Approval Hearing. c. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representative, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counsel. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approvalpreliminary approval. If and only if the Parties are unable to obtain Preliminary Approval preliminary approval of a settlement agreement after submitting at least two renegotiated settlements to the Court, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred. In the event such occurs, the Settlement Administrator shall, upon notice, return all settlement funds to Defendants within 10 days.

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiff will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”)) under the terms specified herein. Contemporaneously with the filing of the Unopposed Motion for Preliminary Approval, Plaintiff will file a Third Amended Complaint conforming her allegations to be consistent with information learned through the Litigation. b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice Claim Form and the forms of notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representativeclass representative, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action as if the Settlement had not occurred.. FILED DATE: 4/29/2021 8:36 PM 2019CH00205

Procedure for Approving Settlement. a. Unopposed Motion for Preliminary Approval of the Settlement by the Court. i. Plaintiff will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to of the Settlement, setting a date for the Final Approval Hearing, and approving the Class Notice and Claim Form (the “Unopposed Motion for Preliminary Approval”). b. ii. At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative and Class Counsel; approving the Notice Claim Form and the forms of notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. iii. For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representativeclass representative for the Class, and that Plaintiff’s Counsel shall be conditionally appointed as Class Counselcounsel for the Class. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it, and the Parties will revert to their prior positions in the Action Litigation as if the Settlement had not occurred.

Procedure for Approving Settlement. a. A. Motion for Preliminary Approval and Conditional Certification. i. Plaintiff will file an unopposed motion move for an order order: (1) conditionally certifying the Class, giving Class for settlement purposes only; (2) granting Preliminary Approval to of the Settlement, ; (3) setting a date for the Final Approval Hearing, hearing; and (4) approving the Notice (the “Unopposed Motion for Preliminary Approval”)Class Notice. b. ii. At the hearing on the Unopposed Motion for Preliminary ApprovalApproval hearing, the Parties Plaintiff will jointly appear, support the granting of the Unopposed Motion for Preliminary Approvalmotion, and submit a proposed order granting conditional certification of the Class and Preliminary Approval of the Settlement AgreementSettlement; appointing the Class Representative and Representative, Class Counsel, and Settlement Administrator; approving the Notice to the Class of the SettlementNotice; and setting the Final Approval Hearinghearing. c. For the purposes iii. Effect of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff shall be conditionally appointed Class Representative, and that Plaintiff’s Counsel shall be conditionally appointed as Class CounselDenial of Preliminary Approval. Should the Court decline to enter conditionally certify the Preliminary Approval Order Class or otherwise decline to preliminarily approve any aspect of the Settlement Agreement, the Parties will attempt to renegotiate those Preliminarily Approve all material aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the CourtSettlement, the Settlement Agreement will be null and void, and the Parties will have no further obligations under it. Provided, however, that the amounts of the Attorneys Fee Award, Cost Award, Administration Costs, and Class Representative Enhancement Payment shall be determined by the Court, and the Parties will revert Court’s determination on these amounts shall be final and binding, and that the Court’s approval or denial of any amount requested for these items are not conditions of this Settlement Agreement, and are to their prior positions in be considered separate and apart from the Action as if fairness, reasonableness, and adequacy of the Settlement had Agreement. Any order or proceeding relating to an application for the Attorneys Fee Award, Cost Award, Administration Costs, and Class Representative Enhancement Payment shall not occurredoperate to terminate or cancel this Settlement Agreement. Nothing in this Agreement shall limit Plaintiff’s or Class Counsel’s ability to appeal any decision by the Court to award less than the requested Attorneys Fee Award, Cost Award, Administration Costs, and Class Representative Enhancement Payment.

Procedure for Approving Settlement. a. Plaintiff (a) Within fourteen (14) days after execution of this Settlement Agreement, Plaintiffs will file an unopposed motion for an order conditionally certifying the Settlement Class, giving Preliminary Approval to granting preliminary approval of the Settlement, appointing Plaintiffs as Class Representatives, appointing Plaintiffs’ Counsel as Class Counsel, setting a date for the 2 Land of Lincoln Legal Aid is among the Chicago Bar Foundation (“CBF”)-supportxx xro bono and legal aid organizations identified as carefully vetted by the CBF through a comprehensive grant review process and considered as qualifying for class action residual funds pursuant to 735 ILCS 5/2-807. See xxxxx://xxxxxxxxxxxxxxxxxxxx.xxx/ pdf/support/cy-pres/state-fact-sheet.pdf. Final Approval Hearing, and approving the form and method of issuing the Settlement Notice (the “Unopposed “Unopposed Motion for Preliminary Approval”Approval”). b. (b) At the hearing on the Unopposed Motion for Preliminary Approval, the Parties will jointly appear, support the granting of the Unopposed Motion for Preliminary Approval, and submit a proposed order granting conditional certification of the Settlement Class and Preliminary Approval preliminary approval of the Settlement AgreementSettlement; appointing the Class Representative Representatives and Class Counsel; approving the Settlement Notice to the Class of the SettlementSettlement Class; and setting the Final Approval Hearing. c. (c) For the purposes of the Settlement and the proceedings contemplated herein only, the Parties stipulate and agree that the Settlement Class shall be conditionally certified in accordance with the definition and on the terms contained above, that Plaintiff Plaintiffs shall be conditionally appointed Class RepresentativeRepresentatives, and that Plaintiff’s Plaintiffs’ Counsel shall be conditionally appointed as Class Counsel. Should the Court decline to enter the Preliminary Approval Order or otherwise decline to preliminarily approve any material aspect of the Settlement Agreement, the Parties will attempt to renegotiate those aspects of the Settlement Agreement in good faith, with the mutual goal of attempting to reach an agreement as close to this Settlement Agreement as possible, and will then submit the renegotiated settlement agreement to the Court for Preliminary Approval. If and only if the Parties are unable to obtain Preliminary Approval of a settlement agreement after submitting at least two renegotiated settlements to the Court, the Settlement Agreement will be null and void, and the Parties will have no further obligations under itthe Settlement Agreement, and the Parties will revert to their prior positions in the Action Litigation as if the Settlement had not occurred.