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

(2) Sixty days after the date of the Notice, the Settlement
Administrator will perform LEXIS-NEXIS credit header searches for all Existing
Opt-In Plaintiffs and Other Eligible Settlement Participants who have not yet
returned the Consent and Release, and
(3) Sixty days after the date of the Notice, Plaintiffs’ Counsel will
telephone and send a reminder letter to each Existing Opt-In Plaintiff and Other
Eligible Settlement Participant who has not yet returned the Consent and Release.
C. Qualified Settlement Fund and Deductions. The Settlement Administrator
will establish a Qualified Settlement Fund and will distribute the settlement amounts to the
Named Plaintiffs, the Existing Opt-In Plaintiffs, Other Eligible Settlement Participants, and
Plaintiffs’ Counsel from the Qualified Settlement Fund as set forth in paragraphs 2 and 3 of this
Agreement. From distributions to the Named Plaintiffs, the Existing Opt-In Plaintiffs, and Other
Eligible Settlement Participants, the Settlement Administrator will deduct federal taxes, the
employee’s share of FICA and Medicare, and applicable state and/or city taxes, and remit those
payments to applicable authorities. The Settlement Administrator will also remit the employer’s
share of FICA, Medicare, FUTA and state unemployment insurance which will be funded by the
Directors. For distributions of attorneys’ fees and expense reimbursements, Plaintiffs’ Counsel
will inform the Settlement Administrator of the amounts payable to each firm.
D. Total Eligible Amount. The “Total Eligible Amount” of the Settlement
shall be $660,000, and shall be deposited by the Directors with the Settlement Administrator as
needed by the Settlement Administrator in order to timely make the distributions provided for in
this Agreement. If the total distributions are less than $660,000, the undistributed balance will
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