SETTLEMENT APPROVAL AND ADMINISTRATION. A. Preliminary and Final Approval. On or before July 14, 2023, and subject to Defendant’s approval, Plaintiffs shall file with the Court an unopposed motion requesting that that the Court preliminarily approve the Settlement and grant class certification of the settlement class under Fed. R. Civ. P. 23. The unopposed motion also will ask the Court to approve the Notice Form and Claim Form prepared by Plaintiffs and Class Counsel and approved by Defendant. Class Counsel shall send the proposed unopposed motion for preliminary approval and Notice Form and Claim Form to Defense Counsel at least five business days before the deadline to file same. Class Counsel agrees she will not file the unopposed motion for preliminary approval and/or Notice Form and Claim Form until the Parties have reached agreement on its content. Class Counsel agrees she will, if necessary, ask the Court for additional time to file the motion and Notice and Claim form if the Parties require additional time to reach agreement on same. At the conclusion of the sixty-day notice period provided in the Notice Form, and prior to the fairness hearing date, and subject to Defendant’s approval, Plaintiffs will file with the Court an unopposed motion for final approval of the Settlement and Proposed Final Order and Judgment dismissing the Action with prejudice (together, “Proposed Final Approval Papers”). Class Counsel will provide Defense Counsel the Proposed Final Approval Papers for Defendant’s approval at least five business days before filing same. Class Counsel agrees she will not file the Proposed Final Approval Papers until the Parties have reached agreement on their content. Class Counsel agrees she will, if necessary, ask the Court for additional time to file the Proposed Final Approval Papers if the Parties require additional time to reach agreement on the same. Plaintiffs, Defendants, and their respective counsel agree to execute all documents necessary to dismiss with prejudice any and all claims raised against Defendant in the Action.
SETTLEMENT APPROVAL AND ADMINISTRATION
