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

Participants who returned signed Consent and Release Forms on or before the Early Deadline,
and (ii) copies of those individuals’ signed Consent and Release Forms (from which their
addresses and social security numbers will be redacted). As to the Existing Opt-In Plaintiffs so
listed, the Second Stipulated Order will ask the Court to approve the issuance of payment to
them. As to the Other Eligible Settlement Participants so listed, the Second Stipulated Order will
ask the Court to grant final approval of the Settlement as to such Other Eligible Settlement
Participants, approve the issuance of payment to them, dismiss their claims with prejudice, and
enter final judgment dismissing them from the Lawsuit and the Related Lawsuit with prejudice,
finding no just reason for delay.
F. Entry of Second Stipulated Order. Entry by the Court of the proposed
Second Stipulated Order is a condition precedent to the implementation of the further steps of the
settlement process described below.
G. Early Settlement Distributions. Within ten (10) days after the entry by the
Court of the Second Stipulated Order, the Settlement Administrator will issue (i) Individual
Payments to the Named Plaintiffs, and to the Existing Opt-In Plaintiffs and Other Eligible
Settlement Participants listed in the Second Stipulated Order, less deductions as provided below
under Settlement Administration, (ii) Service Awards to the Named Plaintiffs of $2,500 each in
recognition of their service as representative plaintiffs, less deductions as provided below under
Settlement Administration, (iii) attorneys’ fees to Plaintiffs’ Counsel in an amount equal to
16.66% of the Individual Payments issued to the Named Plaintiffs and to the Existing Opt-In
Plaintiffs and Other Eligible Settlement Participants listed in the Second Stipulated Order, and
(iv) expense reimbursements to Plaintiffs’ Counsel in the amount of $6,500.
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