SUMMARY OF THE PROPOSED SETTLEMENT. The following description of the proposed Settlement of the Action is only a summary. Reference may be made to the text of the Stipulation, on file with the Court, for a full statement of its provisions. The major terms of the Settlement are as follows.
SUMMARY OF THE PROPOSED SETTLEMENT. A. What Are the Terms of the Settlement? Defendants have agreed to pay $243,000.00 to settle the Litigation (“Gross Settlement Amount”). The Gross Settlement Amount includes attorneys’ fees and costs, costs of settlement administration, PAGA penalties, and the Class Representative Enhancement Payment. The “Net Settlement Fund” is the remainder of the Gross Settlement Amount after the deductions have been made for the following items: (1) up to $81,000 (one-third of the Gross Settlement Amount) for Class Counsel’s attorneys’ fees; (2) Class Counsel’s actual litigation costs; (3) the costs of settlement administration; (4) $20,000 for the PAGA penalties (See Section C(b) below); and (5) up to $7,500.00 to Plaintiff for serving as a Class Representative.
SUMMARY OF THE PROPOSED SETTLEMENT. A. What Are the Terms of the Settlement? Defendants have agreed to pay $450,000.00 to settle the Litigation (“Gross Settlement Amount”). The Gross Settlement Amount includes attorneys’ fees and costs, costs of settlement administration, PAGA penalties, and the Class Representative’s Enhancement Award. The “Net Settlement Fund” is the remainder of the Gross Settlement Amount after the deductions have been made for the following items: (1) up to $150,000 (one-third of the Gross Settlement Amount) for Class Counsel’s attorneys’ fees;
SUMMARY OF THE PROPOSED SETTLEMENT. The parties have agreed to a dismissal with prejudice of the Arbitration and to the following financial terms of a proposed settlement:
SUMMARY OF THE PROPOSED SETTLEMENT. 1. The proposed settlement was reached following substantial discovery, document production and review, and various depositions, as well as a variety of motion practice. Plaintiff and the individual defendants, with the participation of corporate counsel, engaged in settlement communications intermittently from January 2007 into July 2007, and more intensively from July 2007 into August 2007.
SUMMARY OF THE PROPOSED SETTLEMENT. This section includes a summary of the key terms of each section of the Settlement, as well as the Pro Forma PPAs and the Pro Forma PPA amendments included with the Settlement.11 Given the length of the Settlement, this section is only intended to be a summary of key Settlement terms.
SUMMARY OF THE PROPOSED SETTLEMENT. If the Court grants final approval of the Settlement and a final judgment is entered, Ecolab will pay $2,550,000.00 (referred to as the “Settlement Amount”). The Parties agreed to the following payments from the Settlement Amount, subject to Court approval: Penalties to the California Labor Workforce and Development Agency and Private Attorneys General Act Aggrieved Employees. A total of $200,000.00 will be paid in penalties under the PAGA (“PAGA Settlement Amount”). These penalties will be apportioned among the current and former Ecolab employees who worked as TMs and/or HTMs and/or TSRs in California from May 18, 2016 through [date of preliminary approval] (“PAGA Members”). Out of the $200,000.00 in total PAGA penalties to be paid under this Settlement, 75% will be paid to the California Labor Workforce Development Agency and the remaining 25% will be distributed to the PAGA Members (including the Settlement Class Members who participate as PAGA Members).
SUMMARY OF THE PROPOSED SETTLEMENT. If the Settlement Agreement is approved by the Court, U. S. Steel will pay the total amount of $2,000,000 into the Settlement Fund for the benefit and advantage of all Settlement Class Members, each of whom will release his or her claims as set forth in Paragraph 8 below. After the deduction of any court-approved payments
SUMMARY OF THE PROPOSED SETTLEMENT. The Parties were able to reach agreement on all issues and have therefore agreed that, subject to OEB approval of this proposed Settlement Agreement, there are no issues that need to be considered through a hearing. OPG applied to the OEB pursuant to 78.1 of the Ontario Energy Board Act, 1998, for an order or orders approving the disposition of the audited actual balances as of December 31, 2012 in its deferral and variance accounts, except for the balances in the Hydroelectric Incentive Mechanism Variance Account and Hydroelectric Surplus Baseload Generation Variance Account of ($2.4M)1 and $4.1M2 respectively, and a portion of the Capacity Refurbishment Variance Account of $2.4M3. For purposes of settlement, the Parties agreed to defer the consideration of the balance of $30.2M4 in the Nuclear Development Variance Account until OPG’s next Nuclear cost of service application and to forego the recovery of interest charges for certain accounts. In the Application, the December 31, 2012 audited actual balances of OPG’s deferral and variance accounts totaled $1,274.4M5. After the adjustments set out in columns (b) and (d) of Tables 16A and 17A of Attachment 1, the Parties accept the December 31, 2012 audited actual balances for recovery totalling $1,058.3M as set out on an account basis in column (e) of Tables 16A and 17A of Attachment 1 of this Settlement Agreement, consisting of $111.0M for hydroelectric and $947.3M for nuclear deferral and variance accounts. Based on specified recovery periods, in its Application OPG proposed to recover $103.3M6 and $849.4M7 in respect of regulated hydroelectric and nuclear accounts, respectively over 2013 and 1 See Attachment 1, Table 16, line 3, Columns (a) and (g).
SUMMARY OF THE PROPOSED SETTLEMENT. The total settlement amount available to be claimed by Collective Plaintiffs is $2.6 million. That settlement amount is divided into Individual Settlement Awards and Attorneys’ Fees and Costs:
