Reasonable Enhancement Award to the Named Plaintiffs. Class Counsel have stated they will seek approval from the Court for a reasonable enhancement award to the Named Plaintiffs, in a total aggregate amount not to exceed Thirty Thousand Dollars ($30,000), with each of the four Named Plaintiffs receiving $7,500 of that amount. If the Court awards a lesser amount to the Named Plaintiffs, the difference between the amount allocated under this Settlement Agreement and the amount awarded shall be included in the Maximum Distributable Amount (as defined in Section IX.A.5). This payment is in addition to each Named Plaintiffs’ Settlement Share to which she may be entitled (if any) as a member of the Final Settlement Class. The Named Plaintiffs will receive an IRS Form 1099 for the portion of the settlement distributed to him or her that represents his or her respective enhancement payment. The Named Plaintiffs shall be responsible for properly declaring such income to the appropriate taxing authorities and for paying any taxes due on such amounts. In exchange for this enhancement award, the Named Plaintiffs will enter into a binding general release of all known and unknown claims they may have against Defendants.
Reasonable Enhancement Award to the Named Plaintiffs. Class Counsel has stated they will seek approval from the Court for a reasonable enhancement award to the Named Plaintiffs in the amount specified in Section IX(A)(3). The payment is in addition to the Named Plaintiffs’ Settlement Share to which they may be entitled as a member of the Final Settlement Class. The Named Plaintiffs will receive an IRS Form 1099 for the portion of the settlement distributed to them that represents their enhancement payment. The Named Plaintiffs shall be responsible for properly declaring such income to the appropriate taxing authorities, and for paying any taxes due on such amounts. In exchange for their enhancement award, the Named Plaintiffs will enter into a binding release of all claims.
Reasonable Enhancement Award to the Named Plaintiffs. Class Counsel have stated they will seek approval from the Court for a reasonable enhancement award to the Named Plaintiffs, and to the Estate of Xxxxxxx Xxxx, who was formerly a named plaintiff but died during the pendency of the Action, in a total aggregate amount not to exceed a total of Fifty Thousand Dollars ($50,000.00) to be paid out of the Maximum Settlement Amount, and Defendants have agreed not to oppose this request. The Enhancement Award shall be allocated $17,500 each to Xxxxxx Xxxxxx and Xxxxx Xxxxxx, and $15,000 to the Estate of Xxxxxxx Xxxx. If the Court awards a lesser amount to the Named Plaintiffs, the difference between the amount allocated under this Settlement Agreement and the amount awarded shall be included in the Maximum Distributable Amount (as defined in paragraph IX.A.5). This payment is in addition to each Named Plaintiffs’ Settlement Share to which she may be entitled as a member of the Final Settlement Class. The Named Plaintiffs and the Estate of Xxxxxxx Xxxx will receive an IRS Form 1099 for the portion of the settlement distributed to her or it that represents her or its respective enhancement payment. The Named Plaintiffs shall be responsible for properly declaring such income to the appropriate taxing authorities, and for paying any taxes due on such amounts. Any employer’s withholding, payroll or other taxes that might be owed on this payment shall be paid by Defendants. In exchange for this enhancement award, the Named Plaintiffs (including Xx. Xxxx’x estate) will enter into a binding general release of all known and unknown claims they may have against Defendants, subject to a waiver of the protections of Civil Code section 1542.
