How Will The Lawyers Be Paid. Class Counsel will file a petition for the award of Attorneys’ Fees and Costs. This petition will be considered at the Fairness Hearing. Class Counsel has agreed to limit their application for an award of Attorneys’ Fees and Costs to not more than $5,666,666 in fees and $35,000 in costs. The Court will determine what fees and costs will be approved.
How Will The Lawyers Be Paid. Class Counsel will file a petition for the award of Attorneys’ Fees and Costs. This petition will be considered at the Fairness Hearing. Class Counsel has agreed to limit their application for an award of Attorneys’ Fees and Costs to not more than $4,333,333 in fees and $410,000 in costs and Class Counsel will also monitor compliance with the Settlement for three years without charge and has committed to bring an enforcement action, if needed, to enforce the Settlement, also with no charge. The Court will determine what fees and costs will be approved.
How Will The Lawyers Be Paid. Class Counsel will file a motion for the award of attorneys’ fees of not more than 30% of the Settlement Amount, plus reimbursement of expenses incurred in connection with the prosecution of the Action not to exceed $20,000. This motion will be considered at the Fairness Hearing described below.
How Will The Lawyers Be Paid. In connection with the Settlement, the Court will award Class Counsel reasonable attorneys’ fees and expenses out of the Settlement Fund. If you are a Class Member and receive an award from the Settlement Fund, you will not owe any fees or expenses to the lawyers who have represented you as part of the Class. The attorneys’ fees and expenses of Class Counsel, as awarded by the Court, will be paid only from the Settlement Fund and only if and after the Settlement has been approved by the Court. As is routine in class action cases, Class Counsel has filed a motion for an award of attorneys’ fees and expenses already incurred as well as the fees and expenses that will be incurred during the five-year term of the Settlement. In its motion, Class Counsel have requested that the Court award them attorneys’ fees and expenses in the amount of $800,000 (or 5%) of the proposed $16 million monetary settlement, plus $150,000 per year during the five-year term of the Settlement to cover future fees and expenses relating to monitoring and enforcing the Settlement, plus interest accruing on all fees and expenses from the date on which the Settlement is funded until such fees and expenses are disbursed to Class Counsel. Costs of providing notice to the Class will also be paid from the $16 million Settlement Fund. Class Counsel have pursued these claims on behalf of Plaintiff and the Class without receiving any compensation for their services or reimbursement of their out-of-pocket expenses. Class Counsel have undertaken substantial risks in pursuing this matter. They have done so with the understanding that, if they obtained a recovery for the class, their expenses would be reimbursed and they would receive fees from the fund recovered.
How Will The Lawyers Be Paid. As part of the settlement agreement, Class Counsel will seek recovery of up to one-third of the total settlement amount, or $2,916,666.66, in addition to their out-of-pocket litigation costs of up to $300,000. Payment of these attorneys’ fees and out-of-pocket litigation costs will be subject to court approval. Please note, these amounts have already been deducted from your settlement share, and the settlement offer amount listed above will not be subject to any further deductions for attorneys’ fees or costs.
How Will The Lawyers Be Paid. The attorneys’ fees and expenses requested will be the only payment to Lead Counsel and Liaison Counsel for their efforts in achieving this settlement and for their risk in undertaking this representation on a wholly contingent basis. To date, Lead Counsel has not been paid for their services in conducting this litigation on behalf of the Lead Plaintiff and the Class, nor for their out-of-pocket expenses. The fee requested will compensate Lead Counsel for their work in achieving the Settlement Fund and is well within the customary range of fees awarded to class counsel under similar circumstances in other cases of this type. The Court may award less than this amount. Lead Counsel will file papers in support of their fee request on or before [Month Date], 2018 and post copies of such papers on the firm’s website (xxx.xxxxxxx.xxx). Lead Counsel and Liaison Counsel will ask the Court for attorneys’ fees of 25% of the Settlement Fund. They will ask the Court to reimburse them for their out of pocket costs of no more than $250,000, and an award to Lead Plaintiff not to exceed $4,000. RELEASE OF SETTLEMENT
How Will The Lawyers Be Paid. Payments of attorneys’ fees and expenses will not reduce the amounts paid to Settlement Class Members who are entitled to payments under the terms of the Settlement Agreement. Any attorneys’ fees and expenses approved by the Court will be paid by GE separately from the money paid to Settlement Class Members. Settlement Class Counsel will ask the Court to award up to $1,350,000 for (1) attorneys’ fees and costs to Settlement Class Counsel and (2) service awards to Settlement Class Representatives, who are Xxxx Xxxxxxx, Xxxxxx Xxxxxxxx, Xxxxxx Xxxx, Xxxxx Xxxxxx, and Xxxxxx Xxxxxx, in the amount of $5,000 each. Settlement Class Counsel’s request will be available on the Settlement Administrator’s Website at [website] by [14 days before deadline for objections]. GE has agreed not to oppose the request for the award up to these amounts. The Court may award less than these amounts. The costs of notifying Class Members and of administering the proposed settlement will also be borne by GE and will not reduce the amounts paid to Settlement Class Members.
How Will The Lawyers Be Paid. Class Counsel will file a motion for the award of attorneys’ fees of not more than one third (33 1/3%) of the Settlement Amount, plus reimbursement of expenses incurred in connection with the prosecution of the Action. This motion will be considered at the Fairness Hearing described below. OBJECTING TO THE ATTORNEYS’ FEES By following the procedures described in the answer to Question 13, you can tell the Court that you do not agree with the fees and expenses the attorneys intend to seek and ask the Court to deny their motion or limit the award.
How Will The Lawyers Be Paid. The settlement provides that Class Counsel will receive up to Four Million Dollars ($4,000,000) of the Gross Settlement Payment in payment to them of their reasonable attorneys’ fees and costs in pursuing this litigation on behalf of the Named Plaintiffs and the class. The Court will be asked to approve the attorneys’ fees and costs at the Fairness Hearing described on page 8 in the answer to Question 14.
How Will The Lawyers Be Paid. Before final approval of the Settlement, Lead Counsel, on behalf of Plaintiffs’ Counsel, will formally move the Court for an award of attorneys’ fees in an amount not to exceed 30% of the Settlement Fund and for expenses paid or incurred in the Action in an amount not to exceed $25 million, plus interest. In addition, Plaintiffs may seek reimbursement of up to an aggregate amount not to exceed $100,000 for their reasonable costs and expenses incurred in representing the Class. Such sums as may be approved by the Court will be paid from the Settlement Fund. Class Members are not personally liable for any such fees or expenses. The attorneys’ fees and expenses requested will be the only payment to Plaintiffs’ Counsel for their efforts in achieving this Settlement and for their risk in undertaking this representation on a wholly contingent basis. Plaintiffs’ Counsel have been litigating this case for over twelve years without any compensation while simultaneously being at risk of losing everything, including tens of millions of dollars in expenses incurred on behalf of the Class and a lodestar in excess of $100 million resulting from well over 200,000 hours spent prosecuting this Action. The attorneys’ fees requested will compensate Plaintiffs’ Counsel for their work in achieving the Settlement.
