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

(c) Participants who fall within both groups are eligible for
Individual Payments in each of the two categories.
(d) The Individual Payments to the Named Plaintiffs, the
Existing Opt-In Plaintiffs, and the Other Eligible Settlement Participants
are stated in the Schedule of Individual Distributions (Exhibit 4).
(2) Subject to approval by the Court, the total amount of the attorneys’
fees payable to Plaintiffs’ Counsel shall be 16.66% of the Total Eligible Amount,
or $110,000, and Plaintiffs’ Counsel’s have incurred reimbursable litigation
expenses of $6,500;
(3) The sum of $2,500 shall be allocated as a “Service Award” to each
Named Plaintiff in recognition of her service as a representative plaintiff for a
total of $5,000.
F. Payments Discharge Defendants’ Obligations. The payments described in
this paragraph shall be in lieu of and discharge any and all obligations of InkStop, Defendants
and Directors for lost compensation, of any kind and nature, to the Named Plaintiffs and the
Existing Opt-In Plaintiffs, and to Other Eligible Settlement Participants who sign and return the
Consent and Release Form. The payments described in this paragraph are also in full payment of
attorneys’ fees and costs, including the cost of administering and obtaining the Consent and
Releases.
G. Tax Treatment of Payments. All payments to Named Plaintiffs, Existing
Opt-In Plaintiffs, and Other Eligible Settlement Participants shall be reported as wages to the
United States Internal Revenue Service and to other appropriate taxing authorities (“Taxing
Authority” or “Taxing Authorities”) on a Form W-2 issued to each participant with that person’s
13