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. 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 Product, and in exchange for CRA’s release of all liability in connection with the Covered Product, AFC shall make a total settlement payment of twelve thousand dollars ($12,000) (“Total Settlement Amount”) as set forth in this Section 3. No other payment is required by AFC under this Settlement Agreement.
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 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, STRUMBA shall make a total settlement payment of Eighteen Thousand Dollars ($18,000) (“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 STRUMBA 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, Gemini shall make a total settlement payment of sixteen thousand five hundred dollars ($16,500) (“Total Settlement Amount”) as set forth in this Section 3. No other payment is required by Gemini under this Settlement Agreement.
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. Subject to the terms and conditions of this Agreement, including but not limited to section III.F.6, the total amount that AxisPoint will pay under the Settlement (the “Total Settlement Amount”) is $595,000. The Total Settlement Amount is all-inclusive of all payments contemplated under the Settlement, and will cover: (a) all settlement shares to all Participating Class Members; (b) the Class Representative Service Payments; (c) the Class Counsel Fees and Expenses Payment; (d) the Settlement Administrator’s fees and expenses; and (e) the California Claims Payments. Over and above the Total Settlement Amount, AxisPoint shall not assume responsibility for any other fees or expenses incurred by Plaintiffs, Class Counsel, or any third party incurred in implementing the terms and conditions of this Agreement and securing the Judgment pursuant to the Agreement.
Total Settlement Amount. In full satisfaction of all consideration, potential civil penalties, attorneys’ fees, and costs in connection with the Notices and Products, and in exchange for CRA’s release of all liability in connection with the Products as set forth in Sections 4.1 and 4.3 below, POCAS shall make a total settlement payment of Twenty-Three Thousand Seven Hundred Fifty Dollars ($23,750) (“Total Settlement Amount”) within two (2) weeks of the date this Settlement Agreement is fully executed by the Parties. The Total Settlement Amount shall be apportioned into a Civil Penalty, and Attorney’s Fees and Costs, as set forth in Sections 3.2, 3.3, 3.4, and 3.5 below. No other payments are required by POCAS under this Agreement.
