To LWDA. The Parties will apply to the Superior Court for a payment out of the Maximum Settlement Amount to the LWDA of $30,000 (the “LWDA Payment”) as the LWDA’s share of the settlement of statutory penalties paid under this Agreement pursuant to PAGA. If the Superior Court approves an LWDA Payment of less than $30,000, the remainder will be retained in the Maximum Net Settlement Amount.
To LWDA. The Parties agree that the sum of Fifty Thousand Dollars ($50,000) shall be allocated to payment of civil penalties for claims brought under the California Private Attorneys General Act (Labor Code sections 2698 et seq.) (“PAGA”). Seventy-five percent (75%) of the amount allocated to PAGA shall be paid by the Settlement Administrator to the Labor Workforce Development Agency (“LWDA”). Twenty-five percent of the amount allocated to PAGA shall be part of the Net Settlement amount available for distribution to Class Members who submit a timely and valid executed Claim Form. Under this formula,
To LWDA. The Parties will seek approval from the Court for a PAGA payment of $360,000 out of the Gross Settlement Amount, which shall be divided $252,000 from the Xxxxxx Settlement Amount and $108,000 from the Xxxxx/Xxxx Settlement Amount. The $252,000 from the Xxxxxx Settlement Amount shall be allocated $189,000 to the LWDA (the “Xxxxxx LWDA Payment”) as the LWDA’s share of the settlement of civil penalties paid under this Agreement pursuant to the PAGA and $63,000 to the Net Xxxxxx Settlement Amount for distribution to the Participating Class Members in the Xxxxxx Subclass. If the Court approves a PAGA payment of less than $252,000, the remainder will be retained in the Net Xxxxxx Settlement Amount. The $108,000 from the Xxxxx/Xxxx Settlement Amount shall be allocated $81,000 to the LWDA (the “Xxxxx/Xxxx LWDA Payment”) as the LWDA’s share of the settlement of civil penalties paid under this Agreement pursuant to the PAGA and $27,000 to the Net Xxxxx/Xxxx Settlement Amount for distribution to the Participating Class Members in the Xxxxx/Xxxx Subclass. If the Court approves a PAGA payment of less than $108,000, the remainder will be retained in the Net Xxxxx/Xxxx Settlement Amount.
To LWDA. The Parties will seek approval from the Court for a PAGA Payment in the amount of $50,000.00 out of the Gross Settlement Amount, which shall be allocated $37,500.00 as the LWDA’s share for the settlement of civil penalties paid under this Agreement pursuant to the PAGA (the “LWDA Payment”) and $12,500.00 for distribution to the PAGA Group Members who were employed during the PAGA Period (the “PAGA Group Amount”). If the Court approves a PAGA Payment of less than $50,000.00 the remainder will be retained in the Net Settlement Amount for distribution to Participating Class Members.
To LWDA. The Parties will apply to the Court for an LWDA Payment from the Total Settlement Amount of $37,500. This amount reflects value negotiated between the parties, each of whom made an independent assessment as to the likely outcome of Plaintiffs’ PAGA claim. If the Court approves an LWDA Payment of less than $37,500, the remainder will be retained in the Net Settlement Amount.
To LWDA. The Parties will seek approval from the Court for a PAGA payment of $50,000 out of the Gross Settlement Amount, which shall be allocated $37,500 to the LWDA (the “LWDA Payment”) as the LWDA’s share of the settlement of civil penalties paid under this Agreement pursuant to the PAGA and $12,500 to the Net Settlement Amount for distribution to the Participating Class Members. If the Court approves a PAGA Payment of less than $50,000, the other terms of the settlement will remain in effect and the remainder will be retained in the Net Settlement Amount for distribution to Participating Class Members. In the event the LWDA or the Court rejects this allocation, the Parties will meet and confer with the Court and the LWDA to reach a penalty allocation acceptable to all parties that does not materially alter the terms of Settlement, nor require Defendants to pay more than the Gross Settlement Fund.
