Settlement Class Co Clause Samples

Settlement Class Co. Lead Counsel and TJX acknowledge that the Litigation includes six pending lawsuits filed against TJX as putative class actions in Canada (the “Canadian Actions”).3 Each Plaintiff in each of those actions (the “Canadian Plaintiffs”) agrees to the terms of the settlement set forth in this Settlement Agreement, including, without limitation, ¶ 6.1 hereinabove and this ¶ 9.5, as signified by the signature of their counsel herein below. Settlement Class Co-Lead Counsel and TJX, with the Canadian Plaintiffs and the Canadian counsel signing this agreement on their behalf, stipulate and agree to a stay of the Canadian Actions pending implementation of the settlement contained in this Settlement Agreement through the Effective Date, and further stipulate and agree to secure in advance of the Effective Date such orders from the Canadian courts as may be necessary to implement the foregoing stay and further obtain, prior to the 3 Copithorn v. TJX Companies, Inc., et al., Q.B.G. No. 100 of A.D. 2007 (Court of Queen’s Bench of Saskatchewan, Judicial Centre of R▇▇▇▇▇); C▇▇▇▇▇▇▇▇ et al. v. TJX Companies, Inc., et al., Civ. No. 0701-000964 (Court of Queen’s Bench of Alberta, Judicial District of Calgary); Ryley v. TJX Companies, Inc., et al., Civ. N▇. ▇▇ ▇▇▇▇ ▇▇▇▇▇▇▇▇ (Supreme Court of British Columbia); Howick v. TJX Companies, Inc., et al., Civ. No. 0▇-▇▇▇▇▇▇-▇▇▇ (Province of Quebec, District of Montreal); C▇▇▇▇▇▇▇▇ et al. v. TJX Companies, Inc., et al., Civ. No. 07-50449 (Court of Queen’s Bench of Manitoba, Winnipeg Centre); W▇▇▇ et al. v. TJX Companies, Inc., et al., Civ. No. 07-ct-000272CP (Ontario Superior Court of Justice). Effective Date, all orders necessary to dismiss the Canadian Actions with prejudice effective as of and no later than the Effective Date.