Total Settlement Amount. In full satisfaction of all potential civil penalties, attorneys’ fees, costs, and other expenses incurred by CRA and its counsel in connection with the Notice and Covered Products, and in exchange for CRA’s release of all liability in connection with the Covered Products, DONGWON shall make a total settlement payment of nine thousand dollars ($9,000) (“Total Settlement Amount”) as set forth in this Section 3. No other payment is required by DONGWON under this Settlement Agreement.
Total Settlement Amount. 6.1 The “Total Settlement Amount,” in full and complete satisfaction of all Released Claims, shall be up to $175,000,000.00 in monetary and non-monetary relief, comprised of a cash payment of up to $152,500,000.00 (the “Settlement Fund”) and programmatic non-monetary relief, described in Section VII, valued at $22,500,000.00.
Total Settlement Amount. (A) Defendants agree to pay, at the time or times prescribed by Section 5(D) of this Agreement, a maximum of $15,000,000.00 (“Settlement Amount”), which shall cover, resolve, and fully satisfy any and all amounts due under this Agreement, including: (1) Settlement Payments (as defined in Section 3.4) to be paid to Qualified Class Members; (2) attorneys’ fees and costs approved by the Court; (3) court-approved service payments to certain individuals; and (4) the reserve set aside for reasonable costs of settlement administration. Settlement Payments and service payments shall constitute a special award to the FLSA Class, Subclasses, and to the individuals therein receiving a payment and shall not be considered as a payment of overtime, salary, wages, and/or compensation under the terms of any company benefit plan or for any purpose except for tax purposes as described in Section 3.5. Under no circumstances will Defendants be required to pay more than $15,000,000.00, other than interest amounts accruing as described in Section 3.1(B) and amounts due to cover DSG’s share of payroll taxes as described in Section 5(D).
Total Settlement Amount. In full satisfaction of all potential civil penalties, attorneys’ fees, costs, and other expenses incurred by CRA and its counsel in connection with the Notice and Covered Products, and in exchange for CRA’s release of all liability in connection with the Covered Products, POP shall pay a total of $22,000 (Total Settlement Amount) as set forth in this Section. No other payment is required by POP under this Settlement Agreement.
Total Settlement Amount. In full satisfaction of all consideration, potential civil penalties, attorneys’ fees, and costs in connection with the Notices and Covered Products, and in exchange for CRA’s release of all liability in connection with the Products (including as set forth in the Notices) as set forth in Sections 4.1 and 4.3 below, PGF shall make a total settlement payment of Forty Thousand Dollars ($40,000) (“Total Settlement Amount”). The Total Settlement Amount shall be apportioned into a Civil Penalty, Attorney’s Fees and Costs, an Additional Settlement Payment, and a Cost Reimbursement as required by CRA and set forth in Sections 3.2, 3.3, 3.4, and 3.5 below. No other payments are required by PGF under this Agreement.
Total Settlement Amount. (A) Defendant agrees to pay a gross settlement amount of up to a maximum of $1,200,00.00 (the “Total Settlement Fund”), which shall resolve and satisfy: (1) all settlement payments to all Participating Class and Collective Members; (2) a court-approved Service Payment to Plaintiffs Xxxx Xxxx and Xxxxxxx Xxxxxxxx of up to $15,000.00 collectively; (3) the cost of a third-party settlement administration company, including fees incurred during the conditional certification notice process; (4) court-approved attorneys’ fees and out-of-pocket litigation expenses; (5) the Participating Class and Collective Members’ share of employment taxes; and (6) all other costs associated with the settlement other than Defendant’s share of employment taxes. Defendant will not be required to pay more than the Total Settlement Amount under this Agreement. To the extent the Settlement Administrator requires any fees prior to the funding of the settlement, Defendant shall advance those fees which will offset any amount Defendant is subsequently required to fund upon final approval.
Total Settlement Amount. In full satisfaction of all potential civil penalties, attorneys’ fees, costs, and other expenses incurred by CRA and its counsel in connection with the Notices and Products, and in exchange for CRA’s release of all liability in connection with the Products, PALDO shall make a total settlement payment of thirty-eight thousand five hundred dollars ($38,500) (“Total Settlement Amount”) as set forth in this Section 3. No other payment is required by PALDO under this Settlement Agreement.
Total Settlement Amount. Subject to the terms and conditions of this Agreement, the total amount Defendant will pay and/or make available for distribution, in final and complete settlement of the Action, is Two Hundred Fifteen Thousand Dollars and Zero Cents ($215,000.00) (plus the reasonable cost of administration). Subject to approval by the Court, the Total Settlement Amount will be paid and/or made available to Plaintiffs, Opt-Ins, and Plaintiffs’ Counsel as provided in this Paragraph 2.
Total Settlement Amount. In full satisfaction of all potential civil penalties, attorneys’ fees, costs, and other expenses incurred by CRA and its counsel in connection with the Notice and Covered Products, and in exchange for CRA’s release of all liability in connection with the Covered Products, ROCKMAN shall pay a total of $16,500 (Total Settlement Amount) as set forth in this Section. No other payment is required by ROCKMAN under this Settlement Agreement.
Total Settlement Amount. “Total Settlement Amount” refers to the maximum payment 25 Defendant may be obligated to make in connection with the Agreement: $1,150,000.00, except as 26 provided for herein and in Paragraph 3. This maximum sum includes all Individual Settlement Payments, 27 any Service Award, Administrative Costs, and the Class Counsel Award. Defendant shall pay any 28 employer-side payroll taxes owing on the portion of the Total Settlement Amount allocated towards wages 1 on top of and in addition to the Total Settlement Amount.
