Common use of Settlement Formula Clause in Contracts

Settlement Formula. The maximum settlement amount is Two Hundred Seventy-Five Thousand Dollars ($275,000) (the “Maximum Settlement Amount”). The portion of the Maximum Settlement Amount that is available for payment to Class Members is referred to as the “Net Settlement Amount.” The Net Settlement Amount will be the Maximum Settlement Amount less the following payments which are subject to approval by the Court: (1) Attorneys’ Fees and Costs, consisting of attorneys’ fees in an amount not to exceed 35% of the Maximum Settlement Amount (i.e., $96,250) and reimbursement of litigation costs and expenses in an amount not to exceed Thirty-Five Thousand Dollars ($35,000) to Class Counsel; (2) Enhancement Payment in an amount up to Seven Thousand Five Hundred Dollars ($7,500) to Plaintiff for her services in the Action; and (3) Settlement Administration Costs in an amount not to exceed Eighteen Thousand Dollars ($18,000) to the Settlement Administrator. Class Members are eligible to receive payment under the Settlement of their pro rata share of the Net Settlement Amount (“Individual Settlement Share”) based on the number of weeks that each Class Member who did not sign an arbitration agreement was employed by Defendant as an hourly-paid or non-exempt employee in California during the Class Period (“Workweeks”), which will be calculated by the Settlement Administrator using hire and termination dates as an hourly- paid or non-exempt employee during the Class Period as provided in the Class Data and List, counting one workweek for each week in which a Class Member performed any work for Defendant. The Settlement Administrator has divided the Net Settlement Amount by the Workweeks of all Class Members to yield the “Estimated Workweek Value,” and multiplied each Class Member’s individual Workweeks by the Estimated Workweek Value to yield his or her estimated Individual Settlement Share that he or she may be eligible to receive under the Settlement (which is listed in Section III.C below). Class Members who do not submit a valid and timely Request for Exclusion (“Settlement Class Members”) will be issued payment of their final Individual Settlement Share. Each Individual Settlement Share will be allocated as twenty-five percent (25%) wages which will be reported on an IRS Form W2 and seventy-five percent (75%) penalties, interest, and non-wage damages which will be reported on an IRS Form 1099 (if applicable). Each Individual Settlement Share will be subject to reduction for the employee’s share of taxes and withholdings with respect to the wages portion of Individual Settlement Shares, resulting in a net payment to the Settlement Class Members (“Individual Settlement Payment”). If the Court grants final approval of the Settlement, Individual Settlement Payments will be mailed to Settlement Class Members at the address that is on file with the Settlement Administrator. If the address to which this Notice was mailed

Settlement Formula. The maximum settlement amount Total Settlement Amount is Two Million Nine Hundred Seventy-Five Thousand Dollars ($275,0002,900,000.00) (the “Maximum Total Settlement Amount”). The portion of the Maximum Total Settlement Amount that is available for payment to Class Members who do not opt out of this Settlement (“Settlement Class Members”) is referred to as the “Net Settlement Amount.” The Net Settlement Amount will be the Maximum Total Settlement Amount less the following payments which are subject to approval by the Court: : (1) Attorneys’ Fees and Costs, consisting of attorneys’ fees in an amount not of up to exceed thirty-five percent (35% %) of the Maximum Total Settlement Amount (i.e., up to $96,2501,015,000.00) and reimbursement of litigation costs and expenses in an amount not of up to exceed Thirty-Five Forty Thousand Dollars ($35,00040,000.00) to Class CounselCounsel (collectively, “Class Counsel Award”); (2) Enhancement Payment enhancement payment in an amount up not to Seven exceed Twelve Thousand Five Hundred Dollars ($7,50012,500) to Plaintiff Xxxxxxxxx Xxxxx for her his services in the Action(“Enhancement Payment”); and (3) Settlement Administration Costs settlement administration costs in an amount not to exceed Eighteen Twelve Thousand Dollars ($18,00012,000.00) to the Settlement AdministratorAdministrator (“Settlement Administration Costs”); and (4) the allocation of Five Hundred Thousand Dollars ($500,000.00) to settle all claims under PAGA (“PAGA Payment”), of which 75%, or $375,000.00, will be paid to the Labor and Workforce Development Agency (“LWDA”) and the remaining 25%, or $125,000.00, (“PAGA Employee Amount”) will be distributed pro rata to PAGA Employees. Class Members are eligible to receive payment under the Settlement of their a pro rata share of the Net Settlement Amount (“Individual Settlement Share”) based on the number of weeks that each Class Member who did not sign an arbitration agreement was employed by workweeks during which they worked for Defendant as an hourly-paid or non-exempt employee in California during the Class Period (“Workweeks”). Specifically, which will be calculated by the Settlement Administrator shall determine the number of calendar weeks that the Class Member worked during the Class Period, using hire their start and termination end dates worked as an hourly- hourly-paid or non-exempt employee employees of Defendant in California during the Class Period as provided in Period. Each PAGA Employee’s pro rata share of the Class Data and List, counting one workweek for each week in which a Class Member performed any work for Defendant. The Settlement Administrator has divided the Net Settlement PAGA Employee Amount by the Workweeks of all Class Members to yield the “Estimated Workweek Value,” and multiplied each Class Member’s individual Workweeks by the Estimated Workweek Value to yield his or her estimated Individual Settlement Share that he or she may be eligible to receive under the Settlement (which is listed in Section III.C below). Class Members who do not submit a valid and timely Request for Exclusion (“Settlement Class MembersIndividual PAGA Payment”) will be issued payment based on the number of their final Individual Settlement ShareWorkweeks during which they worked for Defendant during the PAGA Period (“PAGA Workweeks”). Each Individual Settlement Share will be allocated as twenty-five twenty percent (2520%) to wages (which will be reported on an IRS Form W2 W2), and seventy-five eighty percent (7580%) to interest, penalties, interest, and other non-wage damages (which will be reported on an IRS Form 1099 (1099, if applicable). Each Individual Settlement Share will be subject to reduction for the employee’s share of taxes and withholdings with respect to the wages wage portion of the Individual Settlement Shares, resulting in a Share. The net payment to the of each Settlement Class Members Member’s Individual Settlement Share (after reduction for the employee’s share of taxes on the wage portion) is referred to as their “Individual Settlement Payment”).” Each Individual PAGA Payment will be allocated as one hundred percent (100%) penalties and wil be reported on IRS Form-1099 (if applicable) by the Settlement Administrator. If the Court grants final approval of the Settlement, Defendants will deposit of fifty percent (50%) of the Total Settlement Amount (i.e., $1,450,000) thirty days after the Settlement is granted final approval and will deposit the remaining fifty percent (50%) eight months after funding the first installment. If the Court grants final approval of the Settlement, Individual Settlement Payments will be mailed to Settlement Class Members at the address that is on file with the Settlement AdministratorAdministrator by way of check following the first deposit of fifty percent (50%) of the Total Settlement Amount and Individual PAGA Payments will be mailed to PAGA Group Members at the address that is on file with the Settlement Administrator by way of check following the second deposit of the remaining fifty percent (50%) of the Total Settlement Amount. If the address to which this Notice was mailedmailed is not correct, or if you move after you receive this Notice, you must provide your correct mailing address to the Settlement Administrator as soon as possible to ensure your receipt of payment that you may be entitled to.

Settlement Formula. The maximum settlement amount consideration is Two Million Three Hundred Seventy-Five Thousand Dollars ($275,0002,300,000) (the “Maximum Gross Settlement Amount”). The portion of the Maximum Gross Settlement Amount that is available for payment to Class Members who do not submit a timely and valid Request for Exclusion (“Settlement Class Members”) is referred to as the “Net Settlement Amount.” The Net Settlement Amount will be the Maximum Gross Settlement Amount less the following payments which are subject to approval by the Court: (1) Attorneys’ Fees and Costs, consisting of attorneys’ fees Costs in an amount not to exceed 35% of the Maximum Gross Settlement Amount (i.e., $96,250805,000 of $2,300,000) for attorneys’ fees and reimbursement of litigation costs and expenses in an amount not to exceed Thirty-Five Fifty Thousand Dollars ($35,00050,000) for reimbursement of reasonable litigation costs and expenses to Class Counsel; (2) Class Representative Enhancement Payment in an the amount up to Seven of Eight Thousand Five Hundred Dollars ($7,5008,500) to Plaintiff for her services in the Action; and (3) Settlement Administration Costs in an the amount not to exceed Eighteen of Two Hundred Fifty Thousand Dollars ($18,000250,000) that is allocated to penalties under PAGA (“PAGA Penalties”); and (4) Settlement Administration Fees and Costs (which are currently estimated not to exceed $15,000). The PAGA Penalties will be distributed 75% ($187,500) to the Settlement Administrator. Labor and Workforce Development Agency (“LWDA Payment”) and the remaining 25% (i.e., $62,500) will be distributed to Class Members on a pro rata basis based on their Workweeks (“Employee PAGA Amount”). Settlement Class Members will be entitled to receive payment under the Settlement of their share of the Net Settlement Amount (“Individual Settlement Payment”) based on the number of weeks that he or she worked for Defendant as a non- exempt employee in California during the Class Period (“Workweeks”). The Settlement Administrator has divided the Net Settlement Amount by the total number of Workweeks worked by all Class Members to yield the “Workweeks Value,” and multiplied each Class Member’s individual number of Workweeks by the Workweeks Value to yield his or her Individual Settlement Payment. Each Individual Settlement Payment shall be allocated as twenty percent (20%) as wages (“wages portion”), and eighty percent (80%) as penalties, interest, and non-wage damages (collectively, the “non-wage portion”). Settlement Class Members will be issued payment of their Individual Settlement Payment after reduction for required employee-side taxes, contributions, and withholdings with respect to the wages portion of the Individual Settlement Payment. The wages portion will be reported by way of IRS Form W-2 and the non-wage portion will be reported by way of IRS Form 1099. All Class Members, regardless of whether they submit a Request for Exclusion, are also eligible to receive payment under the Settlement of their pro rata share of the Net Settlement Employee PAGA Amount (“Individual Settlement Share”) based on the number of weeks that each Class Member who did not sign an arbitration agreement was employed by Defendant as an hourly-paid or non-exempt employee in California during the Class Period (“WorkweeksPAGA Payment”), which will be calculated by the Settlement Administrator using hire and termination dates as an hourly- paid or non-exempt employee during the Class Period as provided in the Class Data and List, counting one workweek for each week in which a Class Member performed any work for Defendant. The Settlement Administrator has divided the Net Settlement Employee PAGA Amount by the total number of Workweeks of worked by all Class Members to yield the “Estimated Workweek PAGA Workweeks Value,” and multiplied each Class Member’s individual number of Workweeks by the Estimated Workweek PAGA Workweeks Value to yield his or her estimated Individual Settlement Share that he or she may be eligible to receive under the Settlement (which is listed in Section III.C below). Class Members who do not submit a valid and timely Request for Exclusion (“Settlement Class Members”) will be issued payment of their final Individual Settlement SharePAGA Payment. Each Individual Settlement Share PAGA Payment will be allocated as twenty-five one hundred percent (25%) wages which will be reported on an IRS Form W2 and seventy-five percent (75100%) penalties, interest, and non-wage damages which will be reported on an IRS Form 1099 (if applicable). Each Individual Settlement Share will be subject to reduction for the employee’s share of taxes and withholdings with respect to the wages portion of Individual Settlement Shares, resulting in a net payment to the Settlement Class Members (“Individual Settlement Payment”). If the Court grants final approval of the Settlement, Individual Settlement Payments will be mailed to each Settlement Class Members Member and Individual PAGA Payments will be mailed to each Class Member at the his or her address that is on file with the Settlement Administrator. If the address to which this Notice was mailedmailed is not correct, or if you move after you receive this Notice, you must make sure to provide your correct mailing address to the Settlement Administrator in a timely fashion, to ensure receipt of payment that you may be entitled to.

Settlement Formula. The maximum total gross settlement amount is Two Eight Hundred SeventyTwenty-Five Thousand Dollars ($275,000825,000.00) (the “Maximum Gross Settlement Amount”). The portion of the Maximum Gross Settlement Amount that is available for payment to Class Members is referred to as the “Net Settlement Amount.” The Net Settlement Amount will be the Maximum Gross Settlement Amount less the following payments payments, which are subject to approval by the Court: (1) Attorneys’ Fees and Costs, consisting of attorneys’ fees in an amount not to exceed 35% of the Maximum Gross Settlement Amount (i.e., $96,250288,750.00) and reimbursement of litigation costs and expenses in an amount not to exceed ThirtySixty-Five Thousand Dollars ($35,00065,000.00), (together, “Attorneys’ Fees and Costs”) to Class Counsel; (2) Enhancement Payment Incentive Awards in an amount up to Seven Twelve Thousand Five Hundred Dollars ($7,50012,000) to Plaintiff for her services in the Action; and (3) Ninety Thousand Dollars ($90,000.00) (“PAGA Settlement Amount”), with Seventy- Five Percent (75%) or Sixty-Seven Thousand Five Hundred Dollars ($67,500.00) of the PAGA Settlement Amount to be paid to the LWDA (“LWDA Payment”) and Twenty-Two Thousand Five Hundred Dollars ($22,500.00) (“PAGA Fund”) to be paid to Aggrieved Employees; (4) Settlement Administration Costs in an amount not to exceed Eighteen Sixteen Thousand Dollars ($18,000) 16,000.00), to the Settlement Administrator, and (5) Defendant’s employer share of payroll taxes and contributions (“Employer Taxes”), currently estimated to be Twenty Thousand Eight Hundred and One Dollars and Seventy-Two Cents ($20,801.72). Class Members are eligible entitled to receive payment under the Settlement of their pro rata share of the Net Settlement Amount (“Individual Settlement Share”) based on the number of weeks that each Class Member who did not sign an arbitration agreement was employed by worked for Defendant as an hourly-paid or non-exempt employee in within California during the Class Period (“Workweeks”), which will . Workweeks are to be calculated by the Settlement Administrator using hire and termination dates as an hourly- paid or non-exempt employee during the information to be provided by Defendant by way of the Class Period as provided in the Class Data and List, counting one workweek for each week in which a Class Member performed any work for Defendant. The Settlement Administrator has divided the Net Settlement Amount by the total number of Workweeks of all Class Members during the Class Period to yield the “Estimated Workweek Value,” and then multiplied each Class Member’s individual Workweeks during the Class Period by the Estimated Workweek Value to yield his or her the estimated Individual Settlement Share that he or she may be eligible to receive under the Settlement (which is listed in Section III.C below). Class Members who do not submit a timely and valid and timely Request for Exclusion (“Settlement Participating Class Members”) will be issued their payment of their final Individual Settlement Share. Each Individual Similarly, Xxxxxxxxx Employees are entitled to receive payment under the Settlement Share will be allocated as twenty-five percent (25%) wages which will be reported on an IRS Form W2 and seventy-five percent (75%) penalties, interest, and non-wage damages which will be reported on an IRS Form 1099 (if applicable). Each Individual Settlement Share will be subject to reduction for the employee’s of their pro rata share of taxes and withholdings with respect to the wages portion of Individual Settlement Shares, resulting in a net payment to the Settlement Class Members PAGA Fund (“Individual PAGA Shares”) based on the number of weeks each Aggrieved Employee worked as an hourly-paid or non-exempt employee in California during the PAGA Period. The Settlement Payment”)Administrator has divided the PAGA Fund by the Workweeks of all Aggrieved Employees during the PAGA Period to yield the “PAGA Workweek Value,” and then multiplied each Aggrieved Employee’s individual Workweeks during the PAGA Period by the PAGA Workweek Value to yield the Individual PAGA Payment he or she is eligible to receive under the Settlement. If the Court grants final approval of the Settlement, Individual Settlement Payments will be mailed to Settlement Class Members at the address that is on file with the Settlement Administrator. If the address to which this Class Notice was mailedmailed is not correct, or if you move after you receive this Class Notice, you must provide your correct mailing address to the Settlement Administrator as soon as possible to ensure your receipt of payment that you may be entitled to under the Settlement.

Settlement Formula. The maximum total gross settlement amount is Two Three Hundred Seventy-Five Thousand Dollars ($275,000300,000) (the “Maximum Gross Settlement Amount”)) to be paid by Defendant in two installment payments. The portion of the Maximum Gross Settlement Amount that is available for payment to Class Members is referred to as the “Net Settlement Amount.” The Net Settlement Amount will be the Maximum Gross Settlement Amount less the following payments payments, which are subject to approval by the Court: (1) Attorneys’ Class Counsel Fees and CostsPayment, consisting of attorneys’ fees in an amount not up to exceed 35% of the Maximum Gross Settlement Amount (i.e., $96,250) 105,000), and Litigation Expenses Payment consisting of reimbursement of litigation costs and expenses in an amount not up to exceed Thirty-Five Thirty Thousand Dollars ($35,00030,000) to Class Counsel; (2) Enhancement Service Payment in an amount up to Seven Thousand Five Hundred Dollars ($7,500) to Plaintiff for her his services in the Action; and (3) PAGA Payment in the amount of Sixty Thousand Dollars ($60,000); and (4) Settlement Administration Costs Expenses in an amount not to exceed Eighteen Eleven Thousand Dollars ($18,00011,000) to the Settlement Administrator. Note: A total of Sixty Thousand Dollars ($60,000.00) from the Gross Settlement Amount has been allocated toward penalties under the Private Attorneys General Act (“PAGA Payment”), of which the LWDA will be paid 75% (i.e., $45,000) (“LWDA Payment”) and the remaining 25% (i.e., $15,000) to be distributed on a pro rata basis to PAGA Group Members based on their Workweeks during the PAGA Period (“PAGA Group Member Amount”). Class Members are eligible to receive payment under the Class Settlement of their pro rata share of the Net Settlement Amount (“Individual Settlement Share”) and PAGA Group Members are eligible to receive payment under the PAGA Settlement of their pro rata share of the PAGA Group Member Amount (“Individual PAGA Payment”) based on the number of weeks that each Class Member who did not sign an arbitration agreement was employed by Defendant as an hourly-paid or and/or non-exempt employee in California during the Class Period and the number of weeks each PAGA Group Member was employed by Defendant as a hourly-paid and/or non-exempt employee in California during the PAGA Period (“Workweeks”), which will be calculated by the Settlement Administrator using hire and termination dates as an hourly- paid or non-exempt employee during the Class Period as provided in the Class Data and List, counting one workweek for each week in which a Class Member performed any work for Defendant. The Settlement Administrator has divided the Net Settlement Amount by the Workweeks of all Class Members during the Class Period to yield the “Estimated Workweek Value,” and multiplied each Class Member’s individual Workweeks during the Class Period by the Estimated Workweek Value to yield his or her estimated Individual Settlement Share that he or she may be eligible to receive under the Settlement (which is listed in Section III.C below). Class Members who do not submit a valid and timely Request for Exclusion (“Settlement Participating Class Members”) will be issued payment of their final Individual Settlement SharePayment. The Settlement Administrator has divided the PAGA Group Member Amount by the Workweeks of all PAGA Group Members during the PAGA Period to yield the “PAGA Workweek Value” and multiplied each PAGA Group Member’s individual Workweeks during the PAGA Period by the PAGA Workweek Value to yield his or her Individual PAGA Payment (which is listed in Section III.C below). Each Individual Settlement Share will be allocated as twenty-five percent (25%) wages 20% wages, which will be reported on an IRS Form W2 W2, and seventy-five percent (75%) 80% interest, penalties, interest, and non-wage damages damages, which will be reported on an IRS Form 1099 (if applicable). Each Individual Settlement Share will be subject to reduction for the employee’s share of taxes and withholdings with respect to the wages portion of the Individual Settlement Shares, resulting in a Shares (the net payment is referred to the Settlement Class Members (as “Individual Settlement Payment”). The employer’s share of payroll taxes and contributions with respect to the wages portion of Individual Settlement Shares shall be paid by Defendant separately and in addition to the Gross Settlement Amount. Individual PAGA Payments will be allocated as one hundred percent (100%) penalties, will not be subject to taxes or withholdings, and will be reported on an IRS Form-1099 (if applicable). If the Court grants final approval of the Settlement, Individual Settlement Payments will be mailed to Settlement Participating Class Members and Individual PAGA Payments will be mailed to PAGA Group Members at the address that is on file with the Settlement Administrator. If the address to which this Notice was mailedmailed is not correct, or if you move after you receive this Notice, you must provide your correct mailing address to the Settlement Administrator as soon as possible to ensure you receive any payment that you may be entitled to under the Settlement.

Settlement Formula. The maximum total gross settlement amount is [Two Hundred Seventy-Eighty Five Thousand Dollars ($275,000) 285,000.00)/[amount to be determined based on Workweeks per Section VIII.B of the Settlement Agreement] (the “Maximum Gross Settlement Amount”). The portion of the Maximum Gross Settlement Amount that is available for payment to Class Members is referred to as the “Net Settlement Amount.” The Net Settlement Amount will be the Maximum Gross Settlement Amount Amount, less the following payments which are subject to approval by the Court: (1) Attorneys’ Fees and Costs, consisting of attorneys’ fees in an amount not to exceed 35% of the Maximum Gross Settlement Amount (i.e., $96,25099,750.00) (“Attorneys’ Fees”) and reimbursement of litigation costs and expenses expenses, in an amount not to exceed Thirty-Five Twenty Thousand Dollars ($35,00020,000.00) (“Attorneys’ Costs”) to Class Counsel; (2) Enhancement Payment Incentive Award in an amount up not to Seven exceed Five Thousand Five Hundred Dollars ($7,5005,000.00) to Plaintiff for her services in the Action; and (3) Settlement Administration Costs Fees in an amount not to exceed Eighteen Twelve Thousand Five Hundred Dollars ($18,00012,500.00) to the Settlement Administrator; and (4) the amount of Twenty Five Thousand Dollars ($25,000) allocated toward civil penalties under the Private Attorneys General Act (“PAGA Allocation”). The PAGA Allocation will be distributed 75% ($18,750.00) to the LWDA (“LWDA Payment”) and the remaining 25% (i.e., $6,250.00) will be distributed to PAGA Group Members (“PAGA Group Member Amount”). Class Members are eligible entitled to receive payment under the Class Settlement of their pro rata share of the Net Settlement Amount (“Individual Settlement Share”) based on the number of weeks that each Class Member who did not sign an arbitration agreement was employed by worked for Defendant as an hourly-paid or , non-exempt employee employees in California during the Class Period (“Workweeks”), which will be calculated by the Settlement Administrator using hire and termination dates as an hourly- paid or non-exempt employee during the Class Period as provided in the Class Data and List, counting one workweek for each week in which a Class Member performed any work for Defendant. The Settlement Administrator has divided the Net Settlement Amount by the total number of Workweeks of all Class Members to yield the (“Estimated Workweek Value,” ”) and multiplied each Class Member’s individual Workweeks by the Estimated Workweek Value to yield arrive at his or her estimated Individual Settlement Share that he or she may be eligible to receive under the Class Settlement (which is listed in Section III.C below). Class Members who do not submit a timely and valid and timely Request for Exclusion (“Settlement Class Members”) will be issued the net payment of their final each Settlement Class Member’s Individual Settlement Share. Each Individual Settlement Share will be allocated as twenty-five percent (25%) wages which will be reported on an IRS Form W2 and seventy-five percent (75%) penalties, interest, and non-wage damages which will be reported on an IRS Form 1099 (if applicable). Each Individual Settlement Share will be subject to after reduction for the employee’s share of taxes and withholdings with respect to the wages portion of the Individual Settlement Shares, resulting in a net payment to the Settlement Class Members Share (“Individual Settlement Payment”). Each Individual Settlement Share will be allocated as twenty percent (20%) wages, which will be reported on an IRS Form W-2, and eighty percent (80%) penalties, interest, and non-wage damages, which will be reported on an IRS Form 1099. Each Individual Settlement Share shall be subject to reduction for the employee’s share of payroll taxes due on the wages portion of Individual Settlement Share. The employer’s share of payroll taxes and contributions in connection with the wages portion of the Individual Settlement Share (“Employer Taxes”) will be paid by Defendant separately and in addition to the Gross Settlement Amount. PAGA Group Members are eligible to receive payment under the PAGA Settlement of their pro rata share of the PAGA Group Member Amount (“Individual PAGA Payment”), based on the number of Workweeks of each PAGA Group Member during the PAGA Period (“PAGA Workweeks”). The Settlement Administrator has divided the PAGA Group Member Amount by the total number of PAGA Workweeks of all PAGA Members (“PAGA Workweek Value”) and multiplied each PAGA Group Member’s individual PAGA Workweeks by the PAGA Workweek Value to arrive at his or her Individual PAGA Payment that he or she may be eligible to receive under the PAGA Settlement (which is listed in Section III.C below). Each Individual PAGA Payment will be allocated as one hundred percent (100%) penalties, which will be reported on an IRS Form 1099 (if applicable). If the Court grants final approval of the Settlement, Defendant will fund the Gross Settlement Amount in three installment payments, over the course of approximately two years, as follows: On or before August 12, 2023, the Settlement Administrator will establish a qualified settlement account for administration of the Settlement (“Settlement Fund Account”) and Defendant will deposit 33.33% of the Gross Settlement Amount (i.e., $95,000) into the Settlement Fund Account (“First Installment”). On or before August 12, 2024, Defendant will deposit 33.33% of the Gross Settlement Amount (i.e., $95,000) plus an amount sufficient to pay Employer Taxes into the Settlement Fund Account (“Second Installment”). o Within ten days after the Second Installment has been deposited, the Settlement Administrator will issue payments as follows: Individual Settlement Payments to Settlement Class Members, Individual PAGA Payments to PAGA Group Members, LWDA Payment to the Labor and Workforce Development Agency, Incentive Award to Plaintiff, and Administration Fee to itself (the Settlement Administrator). On or before August 12, 2025, Defendant will deposit the remaining 33.33% of the Gross Settlement Amount (i.e., $95,000) into the Settlement Fund Account (“Third Installment”). o Within ten days after the Third Installment has been deposited, the Settlement Administrator will issue payment for Attorneys’ Fees and Costs to Class Counsel. If the Court grants final approval of the Settlement, Individual Settlement Payments will be mailed to Settlement Class Members and Individual PAGA Payments will be mailed to PAGA Group Members at the address that is on file with the Settlement Administrator. If the address to which this Class Notice was mailedmailed is not correct, or if you move after you receive this Class Notice, you must provide your correct mailing address to the Settlement Administrator as soon as possible to ensure your receipt of payment that you may be entitled to under the Settlement.