Approval of Class Settlement. A. Following the Parties’ execution of this Agreement, the Parties shall file forthwith a joint motion seeking preliminary approval of the Settlement Agreement. The motion must request the court to: 1. Preliminarily approve the Settlement Agreement as being a fair, reasonable, and adequate settlement within the meaning of Federal Rule of Civil Procedure 23 and applicable law, and consistent with due process; 2. Approve the Notice Plan set forth in section XI.B. below; and 3. Set the date and time of the Fairness Hearing.
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Sources: Settlement Agreement, Settlement Agreement