Common use of Distribution to Class Members Clause in Contracts

Distribution to Class Members. In addition to her share as a Participating Class Member, class representative ▇▇▇▇▇ ▇▇▇▇▇▇▇ will receive $20,000, subject to approval of the Court, to be paid from the Class Member Pool to compensate her for bringing this case, the time she spent on this case and her loss of privacy as a result of serving as the named Plaintiff. ▇▇. ▇▇▇▇▇▇▇ has worked closely with Plaintiffs’ counsel since late 2009 to change the policy at issue. Since the lawsuit was filed in September 2011, she has regularly provided counsel with information and has informed numerous Class Members and other witnesses about the lawsuit. She attended pretrial hearings including the summary judgment hearing, and she attended a mediation in Worcester with then-Magistrate Judge ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇. She answered interrogatories and document requests, many of which were of a highly personal nature, in painstaking detail. She spent many hours preparing for her deposition, which lasted for the full seven hours permitted under the Federal Rules. Although she was released from the WCC in 2011, the lawsuit has required her to continue to focus on painful memories of her time in jail. This payment will be issued at the same time as the distribution payments to Class Members.