Reasonableness of Settlement. The Parties represent and warrant that this Agreement is made in good faith and in full recognition of the implications of such agreement.
Reasonableness of Settlement. The Parties believe that this is a fair, reasonable, and adequate Settlement and have arrived at this Settlement through arms-length negotiations, taking into account all relevant factors, present and potential.
Reasonableness of Settlement. (a) The Parties believe that this is a voluntary, fair, reasonable and adequate Settlement and that the Parties have arrived at this Settlement in good faith, through arms-length negotiations, based upon adequate information, taking into account all relevant factors, present and potential, and after consultation with experienced legal counsel.
(b) The Named Plaintiffs and Class Counsel acknowledge that an adequate factual basis exists to support the Settlement and that, apart from the limited information described in paragraphs III.9(g) and III.9(c), they hereby waive any right to conduct further discovery to assess or confirm the Settlement.
(c) The Named Plaintiffs and Class Counsel have concluded that the Settlement set forth in this Agreement constitutes a fair, reasonable and adequate resolution of the claims that the Named Plaintiffs have asserted against Defendant, including the claims on behalf of the Settlement Class. The Named Plaintiffs and Class Counsel have also concluded that the Settlement set forth in this Agreement promotes the best interests of the Settlement Class.
Reasonableness of Settlement. (a) The Parties believe that this is a voluntary, fair, reasonable and adequate Settlement and that the Parties have arrived at this Settlement in good faith, through arms-length negotiations facilitated by a third-party neutral, based upon adequate information, taking into account all relevant factors, present and potential, and after consultation with experienced legal counsel.
(b) The Named Plaintiffs and Class Counsel acknowledge that an adequate factual basis exists to support the Settlement and that they hereby waive any right to conduct further discovery to assess or confirm the Settlement.
(c) The Named Plaintiffs and Class Counsel have concluded that the Settlement set forth in this Agreement constitutes a fair, reasonable and adequate resolution of the claims that the Named Plaintiffs have asserted or may assert against Defendant, including the claims on behalf of the Settlement Class. The Named Plaintiffs and Class Counsel have also concluded that the Settlement set forth in this Agreement promotes the best interests of the Settlement Class. Named Plaintiffs and Class Counsel arrive at these conclusions after considering the Batra action and the claims presented therein and after participating in arm’s length mediation.
Reasonableness of Settlement. (a) The Parties believe that this is a voluntary, fair, reasonable and adequate Settlement and that the Parties have arrived at this Settlement in good faith, through arms-length negotiations, based upon adequate information, taking into account all relevant factors, present and potential, and after consultation with experienced legal counsel.
(b) The Named Plaintiffs, Class Counsel, the Related Action Plaintiffs, and their counsel acknowledge that an adequate factual basis exists to support the Settlement and that they hereby waive any right to conduct further discovery to assess or confirm the Settlement.
(c) The Named Plaintiffs, Class Counsel, the Related Action Plaintiffs and Related Action Counsel have concluded that the Settlement as amended constitutes a fair, reasonable and adequate resolution of the claims that the Named Plaintiffs have asserted against Defendant, including the claims on behalf of the Settlement Class and Subclass. The Named Plaintiffs, Class Counsel, Related Action Plaintiffs and their counsel have also concluded that the Settlement as amended promotes the best interests of the Settlement Class.
(d) Related Action Plaintiffs represent that they shall not themselves opt out of or object to the settlement of the Litigation, and Related Action Plaintiffs and Related Action Counsel warrant and represent that they shall not encourage or take any action to cause others to opt out of or object to the settlement of the Litigation.
Reasonableness of Settlement. Counsel for the Parties agree and represent to the Court that the settlement described herein is a reasonable compromise of the claims raised in this action and is fair to all Parties and Class Members. Counsel will provide the Court with a full explanation of the basis for this settlement in support of their motion for final approval. For purposes of preliminary approval, counsel represent to the Court that given the risks to Plaintiffs, Class Members, and Defendant in litigating these claims through trial, the enormous costs in dollars and time the trial of this action would require, it is in the best interests of all Parties and Class Members to settle this case at this time and the settlement terms are reasonable.
Reasonableness of Settlement. Plaintiff represents that this is a fair, reasonable, and adequate settlement and has arrived at this settlement through arm’s-length negotiations, taking into account all relevant factors, present and potential.
Reasonableness of Settlement. The Parties to this Agreement acknowledge and agree that the settlement set forth in this Agreement represents a fair, adequate and reasonable compromise of claims under all of the circumstances, including with respect to the complexity, expense and likely duration of litigation, the risks of establishing liability and damages, the uncertainty of the outcome of litigation, the probability of recovery and all other attendant risks to litigation, and that they have determined to enter into this Agreement after investigation and consideration sufficient to inform themselves of the merits of the Settlement.
