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

fees to Plaintiffs’ Counsel in an amount equal to the difference between the total of $110,000 and
the attorneys’ fees issued to Plaintiffs’ Counsel pursuant to paragraph 2(G) above.
3. Settlement Administration
A. Guidelines for Settlement Administration. If the Court approves the
Settlement as to the Named Plaintiffs and Existing Opt-In Plaintiffs and preliminarily approves
the Settlement as to the Other Eligible Settlement Participants by entering the proposed First
Stipulated Order, the Settlement will be administered by both Plaintiffs’ Counsel and Rust
Consulting, Inc. or another third-party administrator selected by the Parties (“Settlement
Administrator”). The costs of the Settlement Administrator, including the costs of establishing
and administering the Qualified Settlement Fund, estimated to be $12,990.00, will be paid by the
Directors. The following are general guidelines for administration:
(1) Counsel for the Parties compiled the List of Other Eligible
Settlement Participants based on a list of allegedly unpaid employees obtained
from the Department of Labor and from the InkStop Bankruptcy Trustee, and the
List of InkStop Store Managers. Counsel for the Parties compiled the list of
InkStop Store Managers based on organizational charts and a payroll record for
the last two years of operation obtained from InkStop’s former payroll servicing
company.
(2) Prior to the mailing of the Notice, lists of the Existing Opt-In
Plaintiffs and Other Eligible Settlement Participants, both with last known
addresses, will be provided to the Settlement Administrator who will make
reasonable efforts to obtain valid current addresses for them through the National
Change of Address Database.
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