Settlement Payments, Counsel Fees, Counsel Costs, Service Awards, And Named Plaintiffs’ Settlement Payments Sample Clauses

Settlement Payments, Counsel Fees, Counsel Costs, Service Awards, And Named Plaintiffs’ Settlement Payments. Subject to the terms of the Final Approval Order and the conditions specified in this Agreement, and in consideration of the mutual covenants and promises set forth herein, Defendants agree to pay the maximum amount of three million dollars ($3,000,000.00) (i.e., the Gross Settlement Sum or GSS). The GSS includes payments to be made to Settlement Class Members in the form of Settlement Payments, Class Counsel’s Fees and Costs, a Service Payment to Plaintiff Ortega, Named Plaintiffs’ Settlement Payments, and the Settlement Expenses. Defendants shall not be required to pay any amounts in addition to the GSS under this Agreement. The Parties agree, subject to Court approval, that the GSS shall be apportioned as follows: