IN THE UNITED STATES DISTRICT COURT FOR ... - Cleveland.com

(3) If an Other Eligible Settlement Participant contacts Plaintiffs’
Counsel, Plaintiffs’ Counsel shall encourage the Other Eligible Settlement
Participant to participate in the Settlement and may discuss the terms of the
Settlement with him or her.
(4) If any former employee of InkStop who is not on the List of
Existing Opt-In Plaintiffs or the List of Other Eligible Settlement Participants
contacts the Settlement Administrator, Plaintiffs’ Counsel or Defendants’ Counsel
prior to the Final Deadline and desires to participate in the settlement,
Defendants’ counsel will consult with Plaintiffs’ Counsel, and then Defendants
and Directors will decide, in their sole discretion, whether to allow the former
employee to participate. If Defendants and Directors decide to allow such a
former employee to participate, he or she will be given an opportunity to sign and
return a Consent and Release Form, and upon doing so will be eligible to receive
an Individual Payment calculated in accordance with this Agreement, which shall
be paid by the Settlement Administrator from any remaining funds described in
Paragraph 3(D) below or from funds provided by the Directors.
B. Steps to Maximize Participation. The Parties and Directors agree that they
share the objective of maximizing participation in the Settlement. In order to do so, the Parties
agree that:
(1) Thirty days after the date of the Notice, the Settlement
Administrator will place automated phone calls to the Other Eligible Settlement
Participants reminding them to sign and return the Consent and Release
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