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

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length negotiations between experienced counsel after substantial investigation. Plaintiffs’ Counsel have informed the Court that they believe the Settlement is fair, reasonable, and adequate and in the best interests of the Named Plaintiffs, the Existing Opt-In Plaintiffs, and Other Eligible Settlement Participants. The Court has considered all relevant factors, including the risk, complexity, expense, and likely duration of the litigation; the extent of investigation and the stage of the proceedings; the amount offered in the Settlement; and the experience and views of counsel for the Parties. 13. The Court approves the Settlement Agreement and its Exhibits, including the proposed Notice and the proposed Consent and Release Form, and orders that the Settlement be implemented according to the terms and conditions of the Settlement Agreement and as directed herein. The Court grants final approval of the Settlement as to the Named Plaintiffs and all Existing Opt-In Plaintiffs. As all Other Eligible Settlement Participants, the Court grants preliminary approval of the Settlement and directs that they be given Notice as provided in the Settlement Agreement. 14. The Court finds that the proposed allocation and calculation of Individual Payments are fair and reasonable. The Court approves the method of calculation and proposed distribution of Individual Payments. The Parties have submitted with the Joint Motion a Schedule of Individual Payments listing the names of all eligible participants and the Individual Payments for which they are eligible. The Court approves the Schedule of Individual Payments and orders that such payments be distributed in the manner, and subject to the terms and conditions, set forth in the Settlement Agreement. 15. The Court approves the Service Awards to the Named Plaintiffs in recognition of their service in the Lawsuits, and orders that such payments be made in the manner, and subject to the terms and conditions, set forth in the Settlement Agreement. 6
16. The Court approves the payment of attorneys’ fees and expense reimbursements to Plaintiffs’ Counsel as provided in the Settlement Agreement, and orders that such payments be made in the manner, and subject to the terms and conditions, set forth in the Settlement Agreement. 17. The Court dismisses the claims of the Named Plaintiffs and the Existing Opt-In Plaintiffs with prejudice, and enters final judgment dismissing them from the Lawsuits. The Court finds there is no just reason for delay and directs the Clerk of the Court to enter this First Stipulated Order and Partial Final Judgment immediately. 18. The Court retains jurisdiction over the Lawsuits for purposes of administration of the Settlement and enforcement of the Settlement Agreement. Date: _________________________ /s/ Jason R. Bristol JASON R. BRISTOL (0072989) jbristol@crklaw.com THOMAS A. DOWNIE (0033119) tdownie@crklaw.com COHEN ROSENTHAL & KRAMER LLP The Hoyt Block Building – Suite 400 700 West St. Clair Avenue Cleveland, OH 44113 (216) 781-7956 [Telephone] (216) 781-8061 [Facsimile] 7 SO ORDERED: ___________________________________ Solomon Oliver United States District Judge SO STIPULATED: /s/ Mitchell G. Blair MITCHELL G. BLAIR (0010892) mblair@calfee.com JOHN R. CERNELICH (0034697) jcernelich@calfee.com CALFEE, HALTER & GRISWOLD LLP 1400 KeyBank Center 800 Superior Avenue Cleveland, OH 44114 (216) 622-8200 [Telephone] (216) 241-0816 [Facsimile]
Page 1 and 2:
MELANIE WARREN and CAROL LASKOSKI,
Page 3 and 4:
MICHAEL SHAUGHNESSY (“Directors
Page 5 and 6: C. The term “Other Eligible Settl
Page 7 and 8: Participants who returned signed Co
Page 9 and 10: fees to Plaintiffs’ Counsel in an
Page 11 and 12: (2) Sixty days after the date of th
Page 13 and 14: (c) Participants who fall within bo
Page 15 and 16: similarly situated employees exists
Page 17 and 18: 12. Governing Law. This Agreement i
Page 23 and 24: LIST OF EXISTING OPT-IN PLAINTIFFS
Page 25 and 26: LIST OF EXISTING OPT-IN PLAINTIFFS
Page 27 and 28: LIST OF OTHER ELIGIBLE SETTLEMENT P
Page 35 and 36: LIST OF INKSTOP STORE MANAGERS NUMB
Page 41 and 42: SCHEDULE OF INDIVIDUAL PAYMENTS (Af
Page 51 and 52: IN THE UNITED STATES DISTRICT COURT
Page 53 and 54: 3. The Named Plaintiffs in the Laws
Page 55: amount $166.72. Participants who fa
Page 59 and 60: NOTICE OF SETTLEMENT OF INKSTOP LAW
Page 61 and 62: CONSENT TO OPT INTO LAWSUIT, RELEAS
Page 63 and 64: 1. The Court previously granted the
Page 65 and 66: jbristol@crklaw.com THOMAS A. DOWNI
Page 67 and 68: 1. The Court previously granted the
Page 69: tdownie@crklaw.com COHEN ROSENTHAL
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IN THE UNITED STATES DISTRICT COURT FOR ... - Cleveland.com

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