Common use of To Class Counsel Clause in Contracts

To Class Counsel. A Class Counsel Fees Payment of not more than %, which is currently estimated to be $ , and a Class Counsel Litigation Expenses Payment of not more than $ . XYZ will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ harmless, and indemnifies XYZ, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $41,667 (Forty-One Thousand Six Hundred Sixty-Seven Dollars) and a Class Counsel Litigation Expenses Payment of not more than $ $38,000 (Thirty-Eight Thousand Dollars). XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than thirty-five percent (35%), which is currently estimated to be $ or $122,500, and a Class Counsel Litigation Expenses Payment of not more than $ $30,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Class Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than one-third (1/3 or 33.33%), which is currently estimated to be $ , one hundred sixteen thousand six hundred sixty-seven dollars ($116,667.00) and a Class Counsel Litigation Expenses Payment of not more than $ thirty thousand dollars and zero cents ($30,000.00). XYZ Defendants will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] days prior to concurrently with Plaintiff’s motion for Final Approval, or the request for Class Counsel Fees Payment and Class Litigation Expenses Payment shall be included within the Final Approval Hearingmotion. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ the Released Parties harmless, and indemnifies XYZthe Released Parties, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 1/3 of the Gross Settlement Amount (33.3333%), which is currently estimated to be $ , $75,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $17,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 1/3 (33.33%), which is currently estimated to be $ $153,333.33, and a Class Counsel Litigation Expenses Payment of not more than $ $16,500. XYZ Defendants will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments. The amounts so awarded shall be for and in complete satisfaction of all attorneys’ fees and costs incurred to date by Plaintiff and/or Class Counsel on behalf of Plaintiff, the Class Members, and the Aggrieved Employees, and of all such future fees and costs, including, but not limited to, fees and costs incurred in documenting this Settlement, securing approval of this Settlement, monitoring this Settlement, reviewing and participating in the settlement administration process, and obtaining the Final Class Judgment and addressing any appeals. The Parties shall otherwise bear all their own fees and costs with respect to the Action and the Agreement.

To Class Counsel. A Class Counsel Fees Payment of not more than 35%, which is currently estimated to be $ , $187,250 and a Class Counsel Litigation Expenses Payment of not more than $ $27,000. XYZ L.A. Southpark will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ L.A. Southpark harmless, and indemnifies XYZ, from any dispute or controversy regarding any division or sharing of any of these Payments.indemnifies

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third of the Gross Settlement Amount, which is currently estimated to be $ , $333,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $30,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ shall hold Defendant harmless, and indemnifies XYZindemnify Defendant, from in any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , thirty-three thousand three hundred thirty-three dollars and thirty-three cents ($33,333.33) and a Class Counsel Litigation Expenses Payment of not more than $ nine thousand five hundred dollars ($9,500.00). XYZ R E I will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ REI harmless, and indemnifies XYZREI, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third of the Gross Settlement Amount ($5,166,666), which is currently estimated to be $ , and a plusa Class Counsel Litigation Expenses Payment of not more than $ Seventy-Thousand Dollars ($75,000.00). XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] days prior to in accordance with Fed. R. Civ. P. 23(h) and the Final Approval Hearingapplicable Local Rules and/or Orders of the Court. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. This Settlement is not contingent upon the Court awarding Class Counsel any particular amount for the Class Counsel Fees Payment or Class Counsel Litigation Expenses Payment, and, in the event that the Court reduces or does not approve the requested amounts, Plaintiff and Class Counsel shall not have the right to modify or revoke the Settlement, or to appeal such order, nor will Plaintiffs or Class Counsel seek, request, or demand an increase to the Gross Settlement Amount on that basis. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from claim or liability for taxes, penalties or interests arising as a result of any payments received by Class Counsel pursuant to this Settlement and from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 3 3 . 3 3 %, which is currently estimated to be $ , $210,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ D e f e n d a n t will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 35 %, which is currently estimated to be $ , $308,000 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ AHF will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ AHF harmless, and indemnifies XYZAHF, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third of the Gross Settlement Amount, which is currently estimated to be $ , $416,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $30,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $272,256.44 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ KPG will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ KPG harmless, and indemnifies XYZKPG, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third of the Gross Settlement Amount, which is currently estimated to be $ , $250,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ $400,000, and a Class Counsel Litigation Expenses Payment of not more than $ $15,000. XYZ Defendants will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ $900,000, and a Class Counsel Litigation Expenses Payment of not more than $ $105,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Fees Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33 1/3%, which is currently estimated to be $ $866,666.67, and a Class Counsel Litigation Expenses Payment of not more than $ $50,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %, one- third of the Gross Settlement Amount which is currently estimated to be $ , $331,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a As part of the motion for Final Approval of Class Action Settlement, Plaintiff will seek Court approval for the Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment no later than [16 court] days prior to the Final Approval HearingPayment. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not no more than %, which is currently estimated to be $ , $350,000 (35% of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not no more than $ $50,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate retain the remainder to the Net Settlement Amount. Any reduction will not be grounds to appeal or otherwise challenge the Court’s approval of this Settlement. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Class Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator may purchase an annuity to utilize U.S. treasuries and bonds or other attorney fee deferral vehicles for Class Counsel. The Administrator will also pay the Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment using one or more IRS 1099 FormsForm 1099. Class Counsel assumes assume full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Payment, hold Released Parties harmless, and indemnifies XYZ, indemnify Released Parties from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than 35%, which is currently estimated to be $ , $99,750.00 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000.00. XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs' Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %(1/3), which is currently estimated to be $ , $133,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs' Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.. / / /

To Class Counsel. A Class Counsel Fees Payment of not more than one-third of the GSA (33.333%), which is currently estimated to be $ , $250,000 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ Defendants will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third, which is currently estimated to be $ , $1,583,333 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ Baxalta will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Baxalta harmless, and indemnifies XYZBaxalta, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %, which is currently estimated to be $ , $143,666.67 (1/3 of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Class Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes assume full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Payment, hold Defendant harmless, and indemnifies XYZindemnify Defendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not no more than %, which is currently estimated to be $ , $40,000 (1/3 of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not no more than $ $25,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. The Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Class Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 FormsForm 1099. Class Counsel assumes assume full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Payment, hold Defendant harmless, and indemnifies XYZ, indemnify Defendant from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $100,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments. Any Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment approved by the Court shall be paid by the Administrator to Class Counsel from the Gross Settlement Amount in two installments: (1) no later than ten (10) business days after Defendant provides the Administrator with the First Installment, the Settlement Administrator will pay Class Counsel 50% of such approved sum; and (2) no later than ten (10) business days after Defendant provides the Settlement Administrator with the Second Installment, the Settlement Administrator will pay Class Counsel the remaining balance of such approved sum.

To Class Counsel. A Class Counsel Fees Payment of not more than 35%, which is currently estimated to be $ , $221,550.00 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s 's Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33 %, which is currently estimated to be $ $100,000, and a Class Counsel Litigation Expenses Payment of not more than $ $17,500. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 35 %, which is currently estimated to be $ , $42,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $813,997.33 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 25.5%, which is currently estimated to be $ , $145,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $12,000.00. XYZ Defendants will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33 %, which is currently estimated to be $ , fifty thousand dollars ($50,000.00) and a Class Counsel Litigation Expenses Payment of not more than $ fourteen thousand dollars ($14,000.00). XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33 %, which is currently estimated to be $ , $150,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000.00. XYZ Ansible will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Ansible harmless, and indemnifies XYZAnsible, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third, which is currently estimated to be $ , $33,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $10,000.00. XYZ Mythical will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Mythical harmless, and indemnifies XYZMythical, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than o n e - third of the Gross Settlement Amount or (33.33 %), which is currently estimated to be $ , three hundred sixty-six thousand six hundred sixty-six dollars and sixty-seven cents ($366,666.67) and a Class Counsel Litigation Expenses Payment of not more than $ sixteen thousand dollars ($16,000.00). XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment Payments no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not no more than %, which is currently estimated to be $ , $293,333.33 (1/3 of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not no more than $ $20,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. The Administrator may purchase an annuity to utilize U.S. treasuries and bonds or other attorney fee deferral vehicles for Class Counsel. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Class Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 FormsForm 1099. Class Counsel assumes assume full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Payment, hold Defendant harmless, and indemnifies XYZ, indemnify Defendant from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $116,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Fees Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant and Released Parties harmless, and indemnifies XYZDefendant and Released Parties, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than one-third (33.33%), which is currently estimated to be $ , Two Hundred Fifty Thousand Dollars and Zero Cents ($250,000.00) and a Class Counsel Litigation Expenses Payment of not more than $ Twenty Thousand Dollars and Zero Cents ($20,000.00). XYZ Defendants will not oppose requests for these payments provided that do not exceed these amountspayments. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If These amounts will cover any and all work performed and any and all costs incurred by Class Counsel in connection with the Court approves Litigation, including without limitation all work performed to date, and all work to be performed and all costs to be incurred in connection with Agreement and administration thereof, as well as any objections raised, and any appeals necessitated by those objections. Class Counsel shall be solely and legally responsible for correctly characterizing this compensation for tax purposes and for paying any taxes on the amounts received. With respect to the Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment, the Settlement Administrator may purchase annuities to utilize United States Treasuries and bonds or other attorney fee deferral vehicles, for Class Counsel. Any additional expenses for the use of attorney fee deferral vehicles shall be paid separately by Class Counsel and shall not be included in the Administration Costs or paid by Defendants. Any portion of the Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder not awarded to Class Counsel shall be part of the Net Settlement Amount. Released Parties shall have no liability Amount to be distributed to Participating Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ harmless, and indemnifies XYZ, from any dispute or controversy regarding any division or sharing of any of these PaymentsMembers.

To Class Counsel. A Class Counsel Fees Payment of not more than 33 %, which is currently estimated to be $ , $61,050.00 and a Class Counsel Litigation Expenses Payment of not more than $ $10,000.00. XYZ XXXX will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ MASI harmless, and indemnifies XYZMASI, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %, one-third which is currently estimated to be $ , One Million Dollars and Zero Cents ($1,000,000.00) and a Class Counsel Litigation Expenses Payment of not more than $ Thirty Two Thousand Dollars and Zero Cents ($32,000.00). XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %, which is currently estimated to be $ , one- third (1/3) of the Gross Settlement Amount and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing, or on another date the Court may set or allow. If This is not a material term of this Settlement, such that if the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ the Released Parties harmless, and indemnifies XYZthe Released Parties, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %33 and 1/3% of the Gross Settlement Amount, which is currently estimated to be $ , $333,300.00 and a Class Counsel Litigation Expenses Payment of not more than $ $90,000. XYZ NHH DEFENDANTS will not oppose requests for these payments provided that the requests do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] 28-days days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Fees Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ NHH DEFENDANTS harmless, and indemnifies XYZNHH DEFENDANTS, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not no more than %, which is currently estimated to be $ , $805,000 (35% of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not no more than $ $20,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount; said reduced approval amount shall not be cause to invalidate the Agreement. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Class Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator may purchase an annuity to utilize U.S. treasuries and bonds or other attorney fee deferral vehicles for Class Counsel. The Administrator will also pay the Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment using one or more IRS 1099 FormsForm 1099. Class Counsel assumes assume full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Payment, hold Defendant harmless, and indemnifies XYZ, indemnify Defendant from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than %33 and 1/3% of the Gross Settlement Amount, which is currently estimated to be $ , $83,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment of less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %, 33 1/3% of the Gross Settlement Amount (which is currently estimated to be $ , $97,755) and a Class Counsel Litigation Expenses Payment of not more than $ $15,000. XYZ UFG will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ UFG harmless, and indemnifies XYZUFG, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %35% of the Gross Settlement Amount, which which, unless increased pursuant to paragraph 8 of this Agreement, is currently estimated to be $ $700,000.00, and a Class Counsel Litigation Expenses Payment of not more than $ $50,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments. There will be no additional charge of any kind to either the Settlement Class Members or request for additional consideration from Defendant for such work unless, Defendant materially breaches this Agreement, including any term regarding funding, and further efforts are necessary from Class Counsel to remedy said breach, including, without limitation, moving the Court to enforce the Agreement.

To Class Counsel. A Class Counsel Fees Payment of not more than 33- 1/3%, which is currently estimated to be $ , $53,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $12,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %33 1/3% of the Gross Settlement Amount, which is currently estimated to be $ i.e., $750,000, and a Class Counsel Litigation Expenses Payment of not more than $ $25,000, both subject to Court Approval. XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for the Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate add the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay issue Class Counsel an IRS Form 1099 for the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 FormsPayment. Class Counsel assumes assume full responsibility and liability for any taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment Payment, and holds XYZ agree to hold Defendants harmless, and indemnifies XYZindemnify Defendants, from any dispute or controversy regarding any division or sharing of any of these PaymentsPayments between or among Class Counsel and/or any other person or entity.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ , $683,333 and a Class Counsel Litigation Expenses Payment of not more than $ $16,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than %One-Third (1/3), which is currently estimated to be $ $188,333, and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not no more than %, which is currently estimated to be $ , $210,000 (35% of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not no more than $ $35,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Class Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes assume full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Payment, hold Defendant harmless, and indemnifies XYZindemnify Defendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ $266,640, and a Class Counsel Litigation Expenses Payment of not more than $ $30,000. XYZ ABR will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s 's Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ ABR harmless, and indemnifies XYZABR, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third of the Gross Settlement Amount, which is currently estimated to be $ , and a Class Counsel Litigation Expenses Payment of not more than $ $10,000.00. XYZ Defendants will not oppose requests for these payments provided that the requests do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %35% of the Gross Settlement Amount, which is currently estimated to be $ , $332,500.00 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33 1/3%, which is currently estimated to be $ , $250,000 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ Defendants will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $366,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $30,000. XYZ Serendib will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility responses and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Serendib harmless, and indemnifies XYZSerendib, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than Thirty-Three and One Third Percent (33 and 1/3%) of the Gross Settlement Amount, which is currently estimated to be $ , Three Hundred and Thirty-Three Thousand Dollars and Zero Cents ($333,000.00) and a Class Counsel Litigation Expenses Payment of not more than $ Twenty Thousand Dollars and Zero Cents ($20,000.00). XYZ Flowserve will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment for less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Flowserve harmless, and indemnifies XYZFlowserve, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %1/3,, which is currently estimated to be $ $170,000.00, and a Class Counsel Litigation Expenses Payment of not more than $ $30,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33 1/3%, which is currently estimated to be $ , $161,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $50,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third of the Gross Settlement Amount, which is currently estimated to be $ $100,000.00, and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. As part of the motion for Final Approval or as a separate motion for Class Counsel Fees Payment and Class Litigation Expenses Payment, Plaintiff and/or Class Counsel will file a motion seek Court approval for any Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than %1/3 of the Gross Settlement Amount, which is currently estimated to be $ , $80,000 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third of the Gross Settlement Amount, which is currently estimated to be $ Nine-Hundred Sixty-Six Thousand, Six-Hundred Sixty-Six Dollars and Sixty-Seven Cents ($966,666.67), and a Class Counsel Litigation Expenses Payment of not more than $ Twenty-Five Thousand Dollars and Zero Cents ($25,000.00). XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33 and 1/3%, which is currently estimated to be $ $40,000, and a Class Counsel Litigation Expenses Payment of not more than $ $15,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ harmless, Defendant harmless and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %_33.33_%, which is currently estimated to be $ , $166,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $85,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %, 35% which is currently estimated to be $ , $388,500.00 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval HearingHearing or other deadline set by the Court. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and the Class Counsel Expenses Payment using one or more in accordance with proper IRS 1099 Formsreporting. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ MSMU harmless, and indemnifies XYZMSMU, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ , $66,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $12,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third, which is currently estimated to be $ , $60,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , Three Hundred Ninety-Five Thousand Two Hundred Eighty Dollars and zero cents ($395,280.00) and a Class Counsel Litigation Expenses Payment of not more than $ Thirteen Thousand Dollars and zero cents ($13,000.00). XYZ Defendant will not oppose requests for these payments provided that the requests do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not thirty-three and one-third percent of the Gross Settlement Amount, or no more than %, which is currently estimated to be $ , Four Hundred Thousand Dollars and Zero Cents ($400,000.00) and a Class Counsel Litigation Expenses Payment of not more than $ Twenty Thousand Dollars and Zero Cents ($20,000.00). XYZ will Defendant shall not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will shall file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment in conjunction with the Motion for Final Approval and/or in any event no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will shall allocate the remainder to the Net Settlement AmountAmount Before Taxes. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any of the Class Counsel Fee Fees Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will shall pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %33 1/3% of the Gross Settlement Amount, which is currently estimated to be $ One Million Dollars ($1,000,000.00), unless increased pursuant to paragraph 9 of this Agreement, and a Class Counsel Litigation Expenses Payment of not more than $ Forty Thousand Dollars ($40,000.00). XYZ Laurel Avenue will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Laurel Avenue harmless, and indemnifies XYZLaurel Avenue, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one third of the Gross Settlement Amount, which is currently estimated to be $ , $350,000 and a Class Counsel Litigation Expenses Payment of not more than $ $40,000. XYZ EVCHC will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ EVCHC harmless, and indemnifies XYZEVCHC, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %, which is currently estimated to be $ , $108,500 (35% of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Class Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes assume full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Payment, hold Defendant harmless, and indemnifies XYZindemnify Defendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ $166,650, and a Class Counsel Litigation Expenses Payment of not more than $ $12,000. XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall will have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ , $108,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts amount(s) requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel counsel arising from any claim to any portion of any Class Counsel Fee Fees Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the judicially approved Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment using one or more IRS 1099 FormsForms 1099. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than %33.33% of the Gross Settlement Amount, which is currently estimated to be $ $666,600.00, and a Class Counsel Litigation Expenses Payment of not more than $ . XYZ will not oppose requests for these payments provided that do not exceed these amounts$20,000.00. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. Defendants will not oppose requests for these payments provided they do not exceed these amounts set forth in this section. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall will have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than %1/3 of the Gross Settlement Amount, which is currently estimated to be $ , $150,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $30,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiff s Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ , $60,833.33 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %35% of the Gross Settlement Amount, which which, unless increased pursuant to paragraph 4.1 of this Agreement, is currently estimated to be $ , Two Hundred Eighty-Eight Thousand Seven Hundred Fifty Dollars and Zero Cents ($288,750.00) and a Class Counsel Litigation Expenses Payment of not more than $ Twenty-Five Thousand Dollars and Zero Cents ($25,000.00). XYZ Defendants will not oppose requests a request for these payments the payment provided that do the request does not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ hold Defendants harmless, and indemnifies XYZindemnify Defendants, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments. A reduction of the Class Counsel Fees Payment and/or Class Counsel Expenses Payment shall not be grounds to nullify this Agreement.

To Class Counsel. A Class Counsel Fees Payment of not more than 3 5 %, which is currently estimated to be $ , $308,000 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ AHF will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ AHF harmless, and indemnifies XYZAHF, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33 and 1/3%, which is currently estimated to be $ Two Hundred Sixty-One Thousand Six Hundred Sixty Six Dollars and Sixty Six Cents ($261,666.66), and a Class Counsel Litigation Expenses Payment of not more than $ Twenty Thousand Dollars and Zero Cents ($20,000). XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ harmless, Defendant harmless and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 35%, which is currently estimated to be $ , $659,750 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than one-third of the GSA (33.333%), which is currently estimated to be $ , $150,000 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than One- Third of the Gross Settlement Amount or 33/1/3%, which is currently estimated to be $ , $183,333.33 (One Hundred Eighty Three Thousand Three Hundred Thirty Three Dollars and 33 Cents) and a Class Counsel Litigation Expenses Payment of not more than $ $15,000 (Fifteen Thousand Dollars and No Cents). XYZ CARGO will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion seek Court approval for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s 's Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ CARGO harmless, and indemnifies XYZCARGO, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %, which is currently estimated to be $ 35% ($1,032,500), and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ Costco will not oppose requests for these payments payments, provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and for Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or or a Class Counsel Litigation Expenses Payment less than the amounts requested, then the Administrator will allocate retain the remainder to in the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for any taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Costco harmless, and indemnifies XYZCostco, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %35% of the Gross Settlement Amount, which is currently estimated to be $ , $240,625 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33 1/3%, which is currently estimated to be $ , $150,000 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000. XYZ TravelStore will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ TravelStore harmless, and indemnifies XYZTravelStore, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third, which is currently estimated to be $ , $83,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ sPower will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] 30 days prior to in advance of the Final Approval HearingResponse Deadline. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ sPower harmless, and indemnifies XYZsPower, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33- 1/3%, which is currently estimated to be $ , $186,598.50 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Counsel’s Fees Payment of not more than %one-third of the Gross Settlement Amount ($833,333.33), which is currently estimated to be $ , and a plus Class Counsel Litigation Counsel’s Expenses Payment of not more than $ Twenty-Five-Thousand Dollars ($25,000.00). XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Counsel’s Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to before the Final Approval Hearing. If the Court approves a an award of Class Counsel Counsel’s Fees Payment and/or a Class Counsel Litigation Expenses Payment in an amount less than the amounts those requested, the Administrator will allocate distribute the remainder to as part of the Net Settlement Amount. This Settlement is not contingent upon the Court awarding Class Counsel any particular amount in Class Counsel’s Fees and/or Expenses, and, if the Court reduces or does not approve the requested amounts, Plaintiff and Class Counsel shall not have the right to modify or revoke the Settlement, or to appeal such order, nor will Plaintiff or Class Counsel seek, request, or demand an increase to the Gross Settlement Amount on that basis. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any of Class Counsel Fee Payment Counsel’s Fees and/or Class Counsel Litigation Expenses Paymentas approved by the Court. The Administrator will pay the Class Counsel Counsel’s Fees Payment and Class Counsel Expenses Payment using one or more IRS Forms 1099 Formsbased on W-9s provided to the Administrator by Class Counsel. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel’s Fees and Expenses and indemnifies and holds Defendant harmless from claims or liability for taxes, penalties or interests arising as a result of any payments received by Class Counsel Fees Payment under this Settlement and the Class Counsel Litigation Expenses Payment and holds XYZ harmless, and indemnifies XYZ, from any dispute or controversy regarding any division or sharing of any of these Paymentssuch payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one- third of the Gross Settlement Amount, which is currently estimated to be $ , $112,500.00 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. As part of the motion for Final Approval or as a separate motion for Class Counsel Fees Payment and Class Litigation Expenses Payment, Plaintiff and/or Class Counsel will file a motion seek Court approval for any Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel DocuSign Envelope ID: 390C4E13-A849-43E2-995A-DFE4F7FA4615 Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel counsel arising from any claim to any portion of any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33 1/3%, which is currently estimated to be $ , $233,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $60,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Subject to Court approval, a Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $306,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 35%, of the Gross Settlement Amount, which is currently estimated to be $ , $52,500.00 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000.00. XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. The amount of the Class Counsel Fees Payment and/or the Class Counsel Litigation Expenses Payment is not a material term of this Agreement and if the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amount requested, it shall not result in the Agreement being void. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Litigation Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %1/3rd , which is currently estimated to be $ , $sixty-six thousand six hundred sixty-six dollars and sixty- seven cents ($66,666.67) and a Class Counsel Litigation Expenses Payment of not more than $ thirty=three thousand dollars ($$33,026.63). XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendants harmless, and indemnifies XYZDefendants, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $413,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third of the Gross Settlement Amount, which is currently estimated to be $ , $83,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ shall hold Defendant harmless, and indemnifies XYZindemnify Defendant, from in any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 33.33%, which is currently estimated to be $ , $66,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000. XYZ ONP will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ ONP harmless, and indemnifies XYZONP, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than 35%, which is currently estimated to be $ , $148,750.00 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendant will not oppose requests for these payments provided that do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] sixteen (16) court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ $357,675, and a Class Counsel Litigation Expenses Payment of not more than $ $95,000. XYZ Defendant will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff Plaintiffs and/or Class Counsel will file a motion for Class Counsel Fees Payment and Class Litigation Expenses Payment no later than [16 court] court days prior to the Final Approval Hearing. If the Court approves a Class Counsel Fees Payment and/or a Class Counsel Litigation Expenses Payment less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount. Released Parties shall have no liability to Class Counsel or any other Plaintiff’s Plaintiffs’ Counsel arising from any claim to any portion any Class Counsel Fee Payment and/or Class Counsel Litigation Expenses Payment. The Administrator will pay the Class Counsel Fees Payment and Class Counsel Expenses Payment using one or more IRS 1099 Forms. Class Counsel assumes full responsibility and liability for taxes owed on the Class Counsel Fees Payment and the Class Counsel Litigation Expenses Payment and holds XYZ Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Paymentspayments.