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 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 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 %, 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 %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.

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 %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 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 %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 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 33.33%, which is currently estimated to be $ , $31,802 and a Class Counsel Litigation Expenses Payment of not more than $ $8,000. 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 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 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 %33.33% of the Gross Settlement Amount, which is currently estimated to be $ , and $91,666.67and a Class Counsel Litigation Expenses Payment of not more than $ $10,000.00. XYZ CTI 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 CTI harmless, and indemnifies XYZCTI, 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 $ , $30,000 (1/3 of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not no more than $ $15,000. 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 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 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 The Class Counsel Fees Payment of not no more than %, which is currently estimated $140,000 to be $ , Class Counsel and a the Class Counsel Litigation Expenses Payment of not no more than $ $15,000 to Class Counsel. 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 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 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 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 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 33.33%, which is currently estimated to be $ $161,650.50, and a Class Counsel Litigation Expenses Payment of not more than $ $10,000. XYZ ProLink 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 portion, any Class Counsel Fee Payment 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 ProLink harmless, and indemnifies XYZProLink, 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% of the Gross Settlement Amount, which is currently estimated to be $ One Hundred Eighteen Thousand, Three Hundred Thirty-Three Dollars ($118,333) and a Class Counsel Litigation Expenses Payment of not more than $ Twenty Thousand Dollars ($20,000). XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. As part of the Motion for Final Approval, Plaintiff and/or Class Counsel will file a motion seek Court approval for any Class Counsel Fees Payment and a Class Counsel 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%, of the Gross Settlement Amount which is currently estimated to be $ , $160,000 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000, equivalent to actual costs expended by Class Counsel in this Action. XYZ Bonobos and Observatory 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 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 hold Defendants harmless, and indemnifies XYZindemnify 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 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 %one-third of the Gross Settlement Amount, which is currently estimated to be $ , One Hundred Fifty Thousand Dollars and Zero Cents ($150,000.00) 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 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 Counsel 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 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 %33 and 1/3% 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 $ $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 Gross Settlement Amount, which is currently estimated to be $ , $116,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $15,000.00. XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff As part of the motion for Final Approval or as a separate motion for Class Counsel Fees Payment and Class Litigation Expenses Payment, Plaintiffs 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 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 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 35%, which is currently estimated to be $ , $53,900 and a Class Counsel Litigation Expenses Payment of not more than $ $9,000. XYZ Public Security 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 Public Security harmless, and indemnifies XYZPublic Security, 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 $ , $89,991.00 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 (1/3) of the Gross Settlement Amount, which is currently estimated to be $ $1,266,666, and a Class Counsel Litigation Expenses Payment of not more than $ $33,000. 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 Paymentspayments.

To Class Counsel. A Class Counsel Fees Payment of not more than %$2 million, which is currently estimated to be $ , 4% of the Combined Monetary Value and a Class Counsel Litigation Expenses Payment of not more than $ $70,000. XYZ Xxxxxxxx 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 by delivery to the Green & Xxxxxx, P.C. Trust Account, including any appropriate 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 Southern harmless, and indemnifies XYZSouthern, 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 $ , 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 $ , $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 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 %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 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 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 %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 more than %one-third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ , $400,000.00 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 do not exceed these amounts. Plaintiff and/or Class Counsel will file a motion for the 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 's 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 Class Counsel Fees Payment and Class Counsel Litigation 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 Defendants harmless, and indemnifies XYZindemnify Defendants, 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 $ , $104,500 (38% of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not no more than $ $15,000. XYZ Defendants 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 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 Defendants harmless, and indemnifies XYZ, indemnify Defendants 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 $ , $245,000 (35% of the Gross Settlement Amount) and a Class Counsel Litigation Expenses Payment of not no 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] 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 Defendants harmless, and indemnifies XYZ, indemnify Defendants 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 $ , $134,986.50 and a Class Counsel Litigation Expenses Payment of not more than $ $30,000. XYZ Defendants will not oppose requests for these payments 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 Attorneys’ Fees Payment and/or a Class Counsel Litigation Expenses Payment Costs 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 PaymentCosts. The Administrator will pay the Class Counsel Attorneys’ 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 Attorneys’ Fees Payment of not more than %33.33% of the Gross Settlement Amount, which is currently estimated to be $ , or $333,300 and a Class Counsel Litigation Expenses Payment Costs of not more than $ $25,000. 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 Released Parties harmless, and indemnifies XYZ, 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 33.3%, which is currently estimated to be $ , $216,450.00 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 do not exceed these amounts. As part of the Final Approval motion, Plaintiff and/or Class Counsel will file a motion for request approval of the Class Counsel Fees Payment and Class 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 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% 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 no more than %, which is currently estimated to be $ , $192,500 (35% 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. 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 33.33%, which is currently estimated to be $ , $50,000.00 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 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 $ Fifty Thousand Dollars even ($50,000.00), and a Class Counsel Litigation Expenses Payment of not more than $ Eleven Thousand Dollars ($11,000.00). 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 %1/3 of the Gross Settlement Amount, which is currently estimated to be $ , Three Hundred Sixteen Thousand Six Hundred Sixty Six Dollars and Sixty Seven Cents ($316,666.67) and a Class Counsel Litigation Expenses Payment of not more than $ Twenty Five Thousand Dollars and No Cents ($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 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 %one-third (1/3) of the Gross Settlement Amount, which is currently estimated to be $ $325,000, and a Class Counsel Litigation Expenses Payment of not more than $ $33,000. 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 of the Gross Settlement Amount, which is currently estimated to be $ , $116,666.67 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000. XYZ Defendants will not oppose requests for these payments provided that they do not exceed these amounts. Plaintiff and/or Class Counsel will include an application for attorneys’ fees in their final approval motion or 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 $ , $750,000.00 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 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 $ , $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 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 thirty-five percent (35%), which is currently estimated to be $ , Four Hundred Twenty Thousand Dollars ($420,000) and a Class Counsel Litigation Expenses Payment of not more than $ Eighteen Thousand Five Hundred Dollars ($18,500). XYZ FSG will not oppose requests or otherwise object to Plaintiff’s application for these payments the Class Counsel Fees Payment and the Class Counsel Litigation Expenses 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 in an amount less than the amounts requested, the Administrator will allocate the remainder to the Net Settlement Amount, which shall be paid to Class Members on a proportional basis relative to the size of their claims as set forth in Paragraph 3.2.4 below. The 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 FSG harmless, and indemnifies XYZFSG, 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 GSA (33.333%), which is currently estimated to be $ , $1,250,000 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] court days prior to the Final Approval Hearing, or as otherwise 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 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 hold Defendant harmless, and indemnifies XYZDefendant, from any dispute or controversy regarding any division or sharing of any of these Payments. Class Counsel shall divide the court approved Class Counsel Fees Payment as follows: 40% to LML, 20% to MY, 20% to SWCK, and 20% to LE.

To Class Counsel. A Class Counsel Fees Payment of not more than %one-third (1/3), which is currently estimated to be $ , $393,333.33 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 %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 no more than %, which is currently estimated to be $ , $1,007,000 (38% 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 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 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 3 3 . 3 3 %, which is currently estimated to be $ , $43,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $5,000.00. XYZ OAS 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 OAS harmless, and indemnifies XYZOAS, 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 $ $113,750, and a Class Counsel Litigation Expenses Payment of not more than $ $10,000.00. 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 3 3 1 / 3 %, which is currently estimated to be $ , $55,000.00 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 (1/3) of the Gross Settlement Amount, which is currently estimated to be $ $186,666, and a Class Counsel Litigation Expenses Payment of not more than $ $12,000. 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 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 $ , $250,000.00 and a Class Counsel Litigation Expenses Payment of not more than $ $25,000.00. XYZ These fees shall be the sole payments for Class Counsel’s work on this case, including carrying out the settlement process and defending the settlement on appeal or other collateral attack, if any. Other than the payments in this Paragraph, the Parties shall bear their own fees and costs. 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 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 33 1/3%, which is currently estimated to be $ , $83,333.33 and a Class Counsel Litigation Expenses Payment of not more than $ $20,000. XYZ Final Phase Construction 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 Final Phase Construction harmless, and indemnifies XYZFinal Phase Construction, 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 $ , One Hundred Thirty-Seven Thousand Five Hundred Dollars ($137,500) and a Class Counsel Litigation Expenses Payment of not more than $ Twenty- Five Thousand Dollars ($25,000). 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 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 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 3 3 . 3 3 %, which is currently estimated to be $ , $223,333.34 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] 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 Xxxxxx Family of Programs, Inc. harmless, and indemnifies XYZXxxxxx Family of Programs, Inc., 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 $ , $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 more than 33.33%, which is currently estimated to be $ , one hundred twelve thousand five hundred dollars ($112,500.00) and a Class Counsel Litigation Expenses Payment of not more than $ ten thousand dollars ($10,000.00). 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] 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 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 $ , $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 %1/3, which is currently estimated to be $ $73,333.33, 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 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.