Common use of Final Approval Hearing Clause in Contracts

Final Approval Hearing. 72. The Parties will recommend that the Final Approval Hearing shall be scheduled no earlier than one hundred (100) Days after the Notice Date. 73. The Parties may file a response to any Objections and a Motion for Final Approval no later than fourteen (14) Days prior to the Final Approval Hearing. 74. Any Settlement Class Member who wishes to appear at the Final Approval Hearing through counsel must, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuit, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered by the Court. 75. Plaintiffs shall ask the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. A finding that the Notice Program fully and accurately informed all Settlement Class Members entitled to notice of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and any other applicable law; b. A finding that after proper notice to the Settlement Class, and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been made, or a finding that all timely objections have been considered and denied; c. Approval of the Settlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 7282. The Parties will recommend that the Final Approval Hearing shall be scheduled no earlier than one hundred fifty (100150) Days after the Notice Preliminary Approval Date. 7383. The Parties may file a response to any Objections and a Motion for Final Approval no later than fourteen (14) Days prior to the Final Approval Hearing. 7484. Any Settlement Class Member who wishes to appear at the Final Approval Hearing through counsel must, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuitLitigation, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered by the Court. 7585. Plaintiffs shall ask the Court to enter a Final Approval Order and Final Judgment Judgment, which includes shall be provided to Defendant in advance for approval as to form, and which shall include the following provisions: a. A finding that the Notice Program fully and accurately informed all Settlement Class Members entitled to notice of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of FloridaOhio, the United States Constitution, and any other applicable law; b. A finding that after proper notice to the Settlement Class, and after sufficient opportunity to object, no timely objections Objections to this Settlement Agreement have been made, or a finding that all timely objections Objections have been considered and denied; c. Approval of the Settlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuitLitigation; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit Litigation and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit Litigation and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 7686. Upon entry of the Final Approval Order, the lawsuit Litigation (including the consolidated action and all Pending Individual Lawsuits listed in Appendix 1) shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 7260. The Parties will recommend that the Final Approval Hearing shall be scheduled no earlier than one hundred (100) 150 Days after the Notice Dateentry of the Preliminary Approval Order, whichever is later. 7361. The Parties may file a response with the Court their briefs regarding final approval, attorneys’ fees, and Service Awards, including responses to any Objections and a Motion for Final Approval Objections, no later than fourteen thirty (1430) Days prior to after the Final Approval HearingObjection Deadline. 7462. Any Settlement Class Member who wishes to appear at the Final Approval Hearing Hearing, whether pro se or through counsel counsel, must, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuitAction, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, in the Long-Form Notice or as otherwise ordered by the Court, and mail that notice and any other such pleadings to Class Counsel and EHS’s Counsel as provided in the Long-Form Notice. 7563. Plaintiffs The Parties shall ask the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. (a) A finding that the Notice Program fully and accurately informed informs all Settlement Class Members entitled to notice of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, due and sufficient notice, and complies fully with the laws of FloridaNew York, the United States Constitution, and any other applicable law;; and, b. (b) A finding that after proper notice to the Settlement Class, and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been made, or a finding that all timely objections have been considered and denied; c. (c) Approval of the Settlementsettlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Class, in all respects, finding that the Settlement settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement settlement in accordance with the terms of this Settlement Agreement; d. (d) A finding that neither the Final Judgment, the Settlement, Judgment nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Partywhatsoever; e. (e) Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuitAction; f. (f) A finding that Plaintiffs shall, shall as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties Persons from the Plaintiffs’ Released Claims; g. (g) A finding that all Settlement Class Members who did not validly and timely opt opting out of the Settlement shall, shall as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties Persons from the Released Class Claims; and h. (h) A reservation of exclusive and continuing jurisdiction over the lawsuit Action and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Preliminary Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. 64. The Court’s exclusive If and continuing jurisdiction over when the lawsuit and Parties shall include, without limitationSettlement becomes Final, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit Action shall be dismissed with prejudice, with the Parties to bear their own costs and attorneys’ fees, costs, costs and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 72. a. The Parties will recommend that the Final Approval Hearing shall be scheduled no earlier than for a date at least one hundred and twenty (100120) Days days after the Notice Dateentry of the Preliminary Approval Order. 73. The Parties may file a response to any Objections and a Motion for Final Approval no b. No later than fourteen seven (147) Days days prior to the Final Approval Hearing, the Settlement Administrator shall file with the Court and serve on counsel for all Parties a declaration stating that the Notice required by the Agreement has been completed in accordance with the terms of the Preliminary Approval Order. 74. Any c. If the Settlement Class Member who wishes to appear at the Final Approval Hearing through counsel must, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuit, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered Agreement is preliminarily approved by the Court. 75. Plaintiffs , and Notice has been sent pursuant to the Agreement, then Plaintiff shall ask file a Motion for Final Approval asking, inter alia, that the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. A finding that the Notice Program fully and accurately informed all Settlement Class Members entitled to notice of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and Judgment. Either Party may file a memorandum addressing any other applicable law; b. A finding that after proper notice objection to the Settlement Class, that has been submitted. Any request by Defendants for entry of the Final Approval Order and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been madeJudgment, or a finding that all timely objections have been considered and denied; c. Approval failure to object to Plaintiff’s request for entry of the SettlementFinal Approval Order and Judgment, shall not be an admission or concession by Defendants as set forth in to any matter pertaining to Plaintiff’s claims. d. At the Settlement AgreementFinal Approval Hearing, the Court will consider and determine whether the provisions of this Agreement should be finally approved as fair, reasonable, and adequate, whether any objections to the Agreement should be overruled, whether the requested Fee Award to Settlement Class Counsel and in the best interests of requested Incentive Payment to the Settlement Class, in all respects, finding that the Settlement is in good faithNamed Plaintiff should be approved, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor whether a judgment finally approving the Settlement Agreement shall constitute an admission should be entered. e. This Settlement Agreement is subject to and conditioned upon the issuance by the Court of liability by any a Final Approval Order that grants final approval of this Agreement and: (i.) finds that the Notice provided satisfies the requirements of Federal Rule of Civil Procedure 23 and due process under the Constitution of the Parties, or any liability or wrongdoing whatsoever by any PartyUnited States; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (hii.) below, a dismissal with prejudice of the lawsuit; f. A finding finds that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly have been adequately represented by the Class Representative and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.Counsel;

Final Approval Hearing. 7292. The Parties will recommend that the Final Approval Hearing shall be scheduled no earlier than one hundred (100) Days 150 days after the Notice Dateentry of the Preliminary Approval Order. 73. The Parties may file a response to any Objections and a Motion for Final Approval no later than fourteen (14) Days prior to the Final Approval Hearing. 7493. Any Settlement Class Member who wishes to appear at the Final Approval Hearing through counsel must, by the Objection Deadline, either hearing must mail or hand-deliver to the Court or file a notice of appearance in the lawsuitAction by the Objection Deadline, and as well as take all other actions or make any additional submissions as may be required by this Settlement Agreement, in the Long Form Notice or as otherwise ordered required by the Court. 7594. Plaintiffs The Parties shall ask the Court to enter a Final Approval Order and Final Judgment which includes including the following provisions: a. A finding that the Notice Program Plan fully and accurately informed informs all Settlement Class Members entitled to notice of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of FloridaFed. R. Civ. P. 23, the United States Constitution, Constitution and any other applicable law; b. A finding that after proper notice to the Settlement ClassClass Members, and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been made, or a finding that all timely objections have been considered and denied; c. Approval of the Settlement, as set forth in the Settlement this Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Classclass, in all respects, finding that the Settlement is in good faith, faith and ordering the Parties and Settlement Administrator parties to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor or the Settlement Agreement shall constitute constitutes an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be Releasing Parties shall have been deemed to have fullyfully and finally release, finallyrelinquish, and forever completely released, relinquished, and discharged discharge the Released Parties from the Plaintiffs’ Released Claims; g. f. A finding that all Settlement Class Members who did have not validly and timely opt properly opted out of the Settlement shallClass are, as of the following entry of the Final Judgment, conclusively be deemed to have fully, finally, fully and forever completely finally released, relinquished, and or discharged the Released Parties from the Released Class Claims; and h. A reservation of exclusive g. If and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, when the Final Approval Order, Order and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitationJudgment is entered, the Court’s power to enforce claims against Defendants in the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit Action shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 72. a. The Parties will recommend request that the Court schedule a Final Approval Hearing shall be scheduled no earlier than one hundred (100) Days after the Notice DateClaims Deadline and Objection Deadline. 73. The Parties may b. Class Counsel shall file their petition for a response Fee Award and Incentive Award no later than thirty (30) days prior to any Objections and the Objection Deadline. c. Class Counsel shall file their motion for entry of a Motion for Final Approval Order and Judgment no later than fourteen (14) Days days prior to the Final Approval Hearing. 74. Any Settlement Class Member who wishes d. No more than fourteen (14) days prior to appear at the Final Approval Hearing through Hearing, the Settlement Administrator shall file with the Court and serve on counsel must, for all Parties a declaration stating that the Notice required by the Objection Deadline, either mail or hand-deliver to Agreement has been completed in accordance with the Court or file a notice terms of appearance in the lawsuit, and take all other actions or make any additional submissions as may be required by this Preliminary Approval Order. e. If the Settlement Agreement, or as otherwise ordered Agreement is preliminarily approved by the Court. 75. Plaintiffs , and all other conditions precedent to the Settlement have been satisfied, then Plaintiff shall ask file a Motion for Final Approval asking, inter alia, that the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. A finding that the Notice Program fully Judgment, with Plaintiff filing a memorandum of points and accurately informed all Settlement Class Members entitled to notice authorities in support of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and motion. Either Party may file a memorandum addressing any other applicable law; b. A finding that after proper notice objection to the Settlement Class, that has been submitted. Any request by Citizens for entry of the Final Approval Order and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been madeJudgment, or a finding that all timely objections have been considered and denied; c. Approval failure to object to Plaintiff’s request for entry of the SettlementFinal Approval Order and Judgment, shall not be an admission or concession by Citizens as set forth in to any matter pertaining to Plaintiff’s claims or the Settlement AgreementAction. f. At the Final Approval Hearing, the Court will consider and determine whether the provisions of this Agreement should be finally approved as fair, reasonable, and adequate, whether any objections to the Agreement should be overruled, whether the requested Fee Award and in the best interests of the Settlement Class, in all respects, finding that the Settlement is in good faithrequested Incentive Award should be approved, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor whether a judgment finally approving the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively should be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims;entered. g. A finding that all This Settlement Class Members who did not validly Agreement is subject to and timely opt out conditioned upon the issuance by the Court of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the a Final Approval Order, and Order that grants final approval of this Agreement and: (i. finds that the Final Judgment; and (ii) supervising Notice provided satisfies the administration and distribution requirements of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.due process;

Final Approval Hearing. 7267. The Parties will recommend that the Final Approval Hearing shall be scheduled no earlier than one hundred thirty (100130) Days after the Notice Dateentry of the Preliminary Approval Order. 7368. The Parties may file a response to any Objections objections and a Motion for Final Approval no later than fourteen (14) Days prior to after the Final Approval HearingObjection Deadline. 7469. Any Settlement Class Member who wishes to appear at the Final Approval Hearing Hearing, whether pro se or through counsel counsel, must, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuitLitigation, and take all other actions or make any additional submissions as may be required by in the Long-Form Notice, this Settlement Agreement, or as otherwise ordered by the Court, and mail that notice and any other such pleadings to Class Counsel and Defendant’s Counsel as provided in the Long-Form Notice. 7570. Plaintiffs The Parties shall ask the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. A finding that the Notice Program fully and accurately informed all Settlement Class Members entitled to notice of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of FloridaCalifornia, the United States Constitution, and any other applicable law; b. A finding that after proper notice to the Settlement Class, and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been made, or a finding that all timely objections have been considered and denied; c. Approval of the Settlementsettlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlementsettlement, nor the Settlement Agreement shall constitute an admission of liability by any of the PartiesParty, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuitLitigation; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties Persons from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties Persons from the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit Litigation and the Parties and Settlement Class Members for the purposes of, among other things, , (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Preliminary Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. 71. The Court’s exclusive If and continuing jurisdiction over when the lawsuit and Parties shall include, without limitationSettlement becomes Final, the Court’s power to enforce Litigation and the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit CAC shall be dismissed with prejudice, with the Parties each Party to bear their its own costs and attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 7278. Other than attorney-client communications or communications otherwise protected from disclosure pursuant to law or rule, the Parties shall promptly provide to each other copies of comments, Objections, Opt-Out Requests, or other documents or filings received from a Settlement Class Member as a result of the Notice Program. 79. The Parties will recommend that the Final Approval Hearing shall should be scheduled no earlier than one hundred and ten (100110) Days after the Notice Dateentry of the Preliminary Approval Order. 7380. The Parties may file a response to any Objections and a Motion for Final Approval objections in further support of final approval no later than fourteen (14) Days prior to the Final Approval HearingFairness Hearing or after receipt of any timely submitted objection, whichever is later. In their discretion, the Parties may respond to late-filed objections, as they deem appropriate. 7481. Any Settlement Class Member who wishes to appear at the Final Approval Hearing Hearing, whether pro se or through counsel counsel, must, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuitLitigation, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, in the Long-Form Notice or as otherwise ordered by the Court, and mail that notice and any other such pleadings to Class Counsel and EHD’s Counsel as provided in the Long-Form Notice. 7582. Plaintiffs The Parties shall ask the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. A finding that the Notice Program fully and accurately informed informs all Settlement Class Members entitled to notice of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of Florida735 ILCS 5/2-803, the United States Constitution, and any other applicable law; b. A finding that after proper notice to the Settlement Class, and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been made, or a finding that all timely objections have been considered and denied; c. Approval of the Settlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Class, in all respects, finding that the Settlement settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (hg) below, a dismissal with prejudice of claims pending against EHD in the lawsuitLitigation; f. A finding that Plaintiffs shall as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Persons from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members not opting out or who have not properly opted out of the Settlement Class shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties Persons from the Plaintiffs’ Released Class Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely releasedare permanently enjoined and barred from continuing in any litigation or asserting any claims against EHD arising out of, relinquishedrelating to, and discharged the Released Parties from or in connection with the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit Litigation and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Preliminary Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. 83. The Court’s exclusive If and continuing jurisdiction over when the lawsuit and Parties shall include, without limitationSettlement becomes Final, the Court’s power to enforce claims against EHD in the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit Litigation shall be dismissed with prejudice, with the Parties to bear their own costs and attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 72. a. The Parties will recommend request that the Court schedule a Final Approval Hearing shall be scheduled no earlier than one hundred (100) Days after the Notice DateClaims Deadline, Objection Deadline and Opt-Out Deadline. 73. The Parties may b. Class Counsel shall file their petition for a response Fee Award and Incentive Award no later than thirty (30) days prior to any Objections and the Objection Deadline. c. Class Counsel shall file their motion for entry of a Motion for Final Approval Order and Judgment no later than fourteen (14) Days days prior to the Final Approval Hearing. 74. Any Settlement Class Member who wishes d. No more than fourteen (14) days prior to appear at the Final Approval Hearing through Hearing, the Settlement Administrator shall file with the Court and serve on counsel must, for all Parties a declaration stating that the Notice required by the Objection DeadlineAgreement has been completed in accordance with the terms of the Preliminary Approval Order. e. No later than fourteen (14) days before the Final Approval Hearing, either mail or hand-deliver to Target shall file with the Court or file a certification that it complied with the CAFA notice requirements and stating the date of appearance in such compliance. f. If the lawsuit, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered Agreement is preliminarily approved by the Court. 75. Plaintiffs , and all other conditions precedent to the Settlement have been satisfied, then Plaintiff shall ask file a Motion for Final Approval asking, inter alia, that the Court to enter a Final Approval Order and Judgment, with Plaintiff filing a memorandum of points and authorities in support of the motion. Either Party may file a memorandum addressing any objection to the Settlement that has been submitted. Any request by Target for entry of the Final Judgment which includes Approval Order and Judgment, or failure to object to Plaintiff’s request for entry of the following provisionsFinal Approval Order and Judgment, shall not be an admission or concession by Target as to any matter pertaining to Plaintiff’s claims or the Action. g. At the Final Approval Hearing, the Court will consider and determine whether the provisions of this Agreement should be finally approved as fair, reasonable, and adequate, whether any objections to the Agreement should be overruled, whether the requested Fee Award and the requested Incentive Award should be approved, and whether a judgment finally approving the Settlement Agreement should be entered. h. This Settlement Agreement is subject to and conditioned upon the issuance by the Court of a Final Approval Order that grants final approval of this Agreement and: a. A finding (i. finds that the Notice Program fully provided satisfies the requirements of Rule 23 of the Federal Rules of Civil Procedure and accurately informed all due process under the Constitution of the United States; (ii. finds that Settlement Class Members entitled to notice of have been adequately represented by the material elements of Class Representative and Class Counsel; (iii. finds that the SettlementSettlement Agreement is fair, constitutes the best notice practicable under the circumstances, constitutes valid, duereasonable, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and any other applicable law; b. A finding that after proper notice adequate to the Settlement Class, that each Settlement Class Member shall be bound by this Agreement, including the releases in Section V, and after sufficient opportunity to object, no timely objections to that this Settlement Agreement have been made, or a finding that all timely objections have been considered should be and deniedis approved; c. Approval of (iv. dismisses on the Settlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, merits and in the best interests with prejudice all claims of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shallasserted against Target, without fees or costs to any Party except as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claimsprovided in this Agreement; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 721. A hearing on final settlement approval (the “Final Approval Hearing”) will be held on , 2024, at before this Court, at , to consider, among other things, the following: (a) determining the fairness, adequacy, and reasonableness of this Agreement and associated settlement pursuant to the applicable Rules of Civil Procedure, applicable law, and other procedural rules or and requirements; and (b) entering the Order of Final Approval. 2. By the Notice Deadline, Class Counsel shall file with the Court any Fee Petition as well as any request by Plaintiff for an incentive award. 3. At least 14 days before the Final Approval Hearing, Class Counsel shall file with the Court any memoranda or other materials in support of final approval of the Agreement and Class Settlement. 4. Any Settlement Class Member who has not filed a Request for Exclusion in the manner set forth above and who also has timely filed an objection may appear at the Final Approval Hearing in person or by counsel and may be heard to the extent allowed by the Court. However, no person shall be heard in opposition to the Agreement and Class Settlement, or the Fee Petition, and no papers or briefs submitted by or on behalf of any such person shall be accepted or considered by the Court, unless that person files such papers and briefs with the Court and serves them upon counsel listed below by the Opt-Out and Objection Deadline. Settlement Class Members who object in the manner and by the dates provided herein and in accordance with section IV above shall be subject to the jurisdiction of this Court. Settlement Class Members who fail to object in the manner and by the dates provided herein and in accordance with section IV above shall be deemed to have waived and shall forever be foreclosed from raising any such objections. 5. Counsel for the Parties who must be served with all documentation described above are as follows: ▇▇▇▇▇ ▇. ▇▇▇▇▇, ▇▇▇. ▇▇▇▇▇ ▇. ▇▇▇▇▇, ▇.▇. ▇▇▇▇ ▇. ▇▇▇▇ ▇▇▇., ▇▇▇. 209A Hollywood, Florida 33020 ▇▇▇▇ ▇. ▇▇▇▇▇▇▇ Lexicon Law, PC ▇▇▇ ▇. ▇▇▇ ▇▇., ▇▇▇▇ ▇▇▇▇▇ Los Angeles, California 90071 ▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇▇▇, LLP ▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇ ▇▇▇▇ Chicago, IL 60606 6. Any Settlement Class Member may hire an attorney at his or her or its own expense to appear in the action. Such attorney shall serve a Notice of Appearance on the Counsel listed above, and file it with the Court, within 60 days after the Notice Deadline. 7. The Parties will recommend that date and time of the Final Approval Hearing shall be scheduled no earlier set forth in the Summary Notice, Full Notice, and the Settlement Website, but shall be subject to adjournment by the Court without further notice to the Settlement Class Members other than one hundred (100) Days after that which may be posted at the Court, on the Court’s website, and/or the Settlement Website to be established pursuant to the Class Notice Dateprogram. 738. The Parties may file a response to any Objections and a Motion for Pending Final Approval no later than fourteen (14) Days prior to the Final Approval Hearing. 74. Any Settlement Class Member who wishes to appear at the Final Approval Hearing through counsel mustApproval, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuit, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered by the Court. 75. Plaintiffs shall ask the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. A finding that the Notice Program fully and accurately informed all Settlement Class Members entitled to notice of the material elements of the Settlementare hereby preliminarily enjoined from, constitutes the best notice practicable under the circumstanceseither directly, constitutes validrepresentatively, due, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and or in any other applicable law; b. A finding that after proper notice capacity (other than a Class Member who validly and timely elects to be excluded from the Settlement Class), and after sufficient opportunity to objectfrom: (a) filing, no timely objections to this Settlement Agreement have been madecommencing, prosecuting, intervening in, or a finding that all timely objections have been considered and denied; c. Approval of the Settlement, participating in (as set forth in the Settlement Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability by class members or otherwise) any action or proceeding based on any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (ib) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against organizing Settlement Class Members’ prosecution , or soliciting the participation of Settlement Class Members, for purposes of pursuing any action or proceeding (including by seeking to amend a pending complaint to include class allegations or seeking class certification in a pending or future action or proceeding) based on any of the Released Claims against Released Parties pursuant to any applicable lawor the facts and circumstances relating thereto. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 7267. The Parties will recommend that the Final Approval Hearing shall be scheduled no earlier than one hundred thirty (100130) Days after the Notice Dateentry of the Preliminary Approval Order. 7368. The Parties may file a response to any Objections objections and a Motion for Final Approval no later than fourteen (14) Days prior to after the Final Approval HearingObjection Deadline. 7469. Any Settlement Class Member who wishes to appear at the Final Approval Hearing Hearing, whether pro se or through counsel counsel, must, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuitLitigation, and take all other actions or make any additional submissions as may be required by in the Long-Form Notice, this Settlement Agreement, or as otherwise ordered by the Court, and mail that notice and any other such pleadings to Class Counsel and Defendant’s Counsel as provided in the Long-Form Notice. 7570. Plaintiffs The Parties shall ask the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. A finding that the Notice Program fully and accurately informed all Settlement Class Members entitled to notice of the material elements of the Settlementsettlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of FloridaWisconsin, the United States Constitution, and any other applicable law; b. A finding that after proper notice to the Settlement Class, and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been made, or a finding that all timely objections have been considered and denied; c. Approval of the Settlementsettlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Class, in all respects, finding that the Settlement settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlementsettlement, nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (hg) below, a dismissal with prejudice of the lawsuitLitigation; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties Persons from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties Persons from the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit Litigation and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Preliminary Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. 71. The Court’s exclusive If and continuing jurisdiction over when the lawsuit and Parties shall include, without limitationSettlement becomes Final, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit Litigation shall be dismissed with prejudice, with the Parties to bear their own costs and attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 72. a. The Parties will recommend request that the Court schedule a Final Approval Hearing shall be scheduled no earlier than one hundred (100) Days after the Notice DateClaims Deadline, Objection Deadline and Opt-Out Deadline. 73. The Parties may b. Class Counsel shall file their petition for a response Fee Award and Incentive Award no later than thirty (30) days prior to any Objections and the Objection Deadline. c. Class Counsel shall file their motion for entry of a Motion for Final Approval Order and Judgment no later than fourteen (14) Days days prior to the Final Approval Hearing. 74. Any Settlement Class Member who wishes d. No more than fourteen (14) days prior to appear at the Final Approval Hearing through Hearing, the Settlement Administrator shall file with the Court and serve on counsel must, for all Parties a declaration stating that the Notice required by the Objection Deadline, either mail or hand-deliver to Agreement has been completed in accordance with the Court or file a terms of the Preliminary Approval Order and that notice of appearance was completed in accordance with CAFA. e. If the lawsuit, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered Agreement is preliminarily approved by the Court. 75. Plaintiffs , and all other conditions precedent to the Settlement have been satisfied, then Plaintiff shall ask file a Motion for Final Approval asking, inter alia, that the Court to enter a Final Approval Order and Judgment, with Plaintiff filing a memorandum of points and authorities in support of the motion. Either Party may file a memorandum addressing any objection to the Settlement that has been submitted. Any request by Naturelo for entry of the Final Judgment which includes Approval Order and Judgment, or failure to object to Plaintiff’s request for entry of the following provisionsFinal Approval Order and Judgment, shall not be an admission or concession by Naturelo as to any matter pertaining to Plaintiff’s claims or the Action. f. At the Final Approval Hearing, the Court will consider and determine whether the provisions of this Agreement should be finally approved as fair, reasonable, and adequate, whether any objections to the Agreement should be overruled, whether the requested Fee Award and the requested Incentive Award should be approved, and whether a judgment finally approving the Settlement Agreement should be entered. g. This Settlement Agreement is subject to and conditioned upon the issuance by the Court of a Final Approval Order that grants final approval of this Agreement and: a. A finding (i. finds that the Notice Program fully provided satisfies the requirements of Rule 23 of the Federal Rules of Civil Procedure and accurately informed all due process under the Constitution of the United States; (ii. finds that Settlement Class Members entitled to notice of have been adequately represented by the material elements of Class Representative and Class Counsel; (iii. finds that the SettlementSettlement Agreement is fair, constitutes the best notice practicable under the circumstances, constitutes valid, duereasonable, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and any other applicable law; b. A finding that after proper notice adequate to the Settlement Class, that each Settlement Class Member shall be bound by this Agreement, including the releases in Section V, and after sufficient opportunity to object, no timely objections to that this Settlement Agreement have been made, or a finding that all timely objections have been considered should be and deniedis approved; c. Approval of (iv. dismisses on the Settlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, merits and in the best interests with prejudice all claims of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shallasserted against Naturelo, without fees or costs to any Party except as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claimsprovided in this Agreement; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 72. a. The Parties will recommend request that the Court schedule a Final Approval Hearing shall be scheduled no earlier than one hundred (100) Days after the Notice DateClaims Deadline, Objection Deadline and Opt-Out Deadline. 73. The Parties may b. Class Counsel shall file their petition for a response Fee Award and Incentive Award no later than thirty (30) days prior to any Objections and the Objection Deadline. c. Class Counsel shall file their motion for entry of a Motion for Final Approval Order and Judgment no later than fourteen (14) Days days prior to the Final Approval Hearing. 74. Any Settlement Class Member who wishes d. No more than fourteen (14) days prior to appear at the Final Approval Hearing through Hearing, the Settlement Administrator shall file with the Court and serve on counsel must, for all Parties a declaration stating that the Notice required by the Objection DeadlineAgreement has been completed in accordance with the terms of the Preliminary Approval Order. e. No later than fourteen (14) days before the Final Approval Hearing, either mail or hand-deliver to ▇▇▇▇▇▇ shall file with the Court or file a certification that it complied with the CAFA notice requirements and stating the date of appearance in such compliance. f. If the lawsuit, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered Agreement is preliminarily approved by the Court. 75. Plaintiffs , and all other conditions precedent to the Settlement have been satisfied, then Plaintiff shall ask file a Motion for Final Approval asking, inter alia, that the Court to enter a Final Approval Order and Judgment, with Plaintiff filing a memorandum of points and authorities in support of the motion. Either Party may file a memorandum addressing any objection to the Settlement that has been submitted. Any request by ▇▇▇▇▇▇ for entry of the Final Judgment which includes Approval Order and Judgment, or failure to object to Plaintiff’s request for entry of the following provisionsFinal Approval Order and Judgment, shall not be an admission or concession by ▇▇▇▇▇▇ as to any matter pertaining to Plaintiff’s claims or the Action. g. At the Final Approval Hearing, the Court will consider and determine whether the provisions of this Agreement should be finally approved as fair, reasonable, and adequate, whether any objections to the Agreement should be overruled, whether the requested Fee Award and the requested Incentive Award should be approved, and whether a judgment finally approving the Settlement Agreement should be entered. h. This Settlement Agreement is subject to and conditioned upon the issuance by the Court of a Final Approval Order that grants final approval of this Agreement and: a. A finding (i. finds that the Notice Program fully provided satisfies the requirements of Rule 23 of the Federal Rules of Civil Procedure and accurately informed all due process under the Constitution of the United States; (ii. finds that Settlement Class Members entitled to notice of have been adequately represented by the material elements of Class Representative and Class Counsel; (iii. finds that the SettlementSettlement Agreement is fair, constitutes the best notice practicable under the circumstances, constitutes valid, duereasonable, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and any other applicable law; b. A finding that after proper notice adequate to the Settlement Class, that each Settlement Class Member shall be bound by this Agreement, including the releases in Section V, and after sufficient opportunity to object, no timely objections to that this Settlement Agreement have been made, or a finding that all timely objections have been considered should be and deniedis approved; c. Approval of (iv. dismisses on the Settlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, merits and in the best interests with prejudice all claims of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shallasserted against ▇▇▇▇▇▇, without fees or costs to any Party except as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claimsprovided in this Agreement; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 7271. The Parties will recommend that the Final Approval Hearing shall be scheduled no earlier than one hundred sixty (100160) Days after the Notice Dateentry of the Preliminary Approval Order. 7372. The Parties may file a response to any Objections and a Motion for Final Approval no later than fourteen (14) Days prior to before the Final Approval Hearing. 7473. Any Settlement Class Member who wishes to appear at the Final Approval Hearing through counsel must, by the Objection Deadline, either mail or hand-deliver to the Court or file a notice of appearance in the lawsuit, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered by the Court. 75. Plaintiffs Counsel shall ask the Court to enter a Final Approval Order and Final Judgment which includes the following provisionswhich: a. A finding Finds that the Notice Program fully and accurately informed all Settlement Class Members entitled to notice of the material elements of the Settlement, ; constitutes the best notice practicable under the circumstances, ; constitutes valid, due, and sufficient notice, ; and complies fully with the laws of FloridaMinnesota, the United States Constitution, and any other applicable law; b. A finding Finds that after proper notice to the Settlement Class, and after sufficient opportunity to object, no timely objections Objections to this Settlement Agreement have been made, made or a finding that all timely objections Objections have been considered and denied; c. Approval Approves of the Settlement, as set forth in the this Settlement Agreement, as fair, reasonable, adequate, and in the best interests of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding Finds that neither the Final Approval Order and Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability or wrongdoing by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (hg) below, a dismissal dismisses the Litigation with prejudice of the lawsuitprejudice; f. A finding Finds that Plaintiffs and all Settlement Class Members shall, as of the entry of the Final Approval Order and Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties Persons from the Released Class Claims; and h. A reservation of g. Reserves exclusive and continuing jurisdiction over the lawsuit Litigation and the Parties for the purposes of, among other things, : (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, Agreement and the Final Approval Order, Order and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class Fund and resolving any disputes that may arise with regard to the foregoing. The Court’s 's exclusive and continuing jurisdiction over the lawsuit Litigation and Parties shall include, without limitation, the Court’s 's power to enforce the bar against Settlement Class Members’ ' prosecution of Released Claims against Released Parties Persons pursuant to the All Writs Act, 28 U.S.C. § 1651, or any other applicable law. 7674. Upon entry of If and when the Final Approval OrderSettlement becomes Final, the lawsuit Litigation shall be dismissed with prejudice, with the Parties to bear their own attorneys’ ' fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 72. a. The Parties will recommend request that the Court schedule a Final Approval Hearing shall be scheduled no earlier than one hundred (100) Days after the Notice DateClaims Deadline and Objection Deadline. 73. The Parties may b. Class Counsel shall file their petition for a response Fee Award and Incentive Awards no later than thirty (30) days prior to any Objections and the Objection Deadline. c. Class Counsel shall file the motion for entry of a Motion for Final Approval Order and Judgment no later than fourteen (14) Days days prior to the Final Approval Hearing. 74. Any Settlement Class Member who wishes d. No more than fourteen (14) days prior to appear at the Final Approval Hearing through Hearing, the Settlement Administrator shall file with the Court and serve on counsel must, for all Parties a declaration stating that the Notice required by the Objection Deadline, either mail or hand-deliver to Agreement has been completed in accordance with the Court or file a notice terms of appearance in the lawsuit, and take all other actions or make any additional submissions as may be required by this Preliminary Approval Order. e. If the Settlement Agreement, or as otherwise ordered Agreement is preliminarily approved by the Court. 75. , and all other conditions precedent to the Settlement have been satisfied, then Plaintiffs shall ask file a Motion for Final Approval asking, inter alia, that the Court to enter a Final Approval Order and Judgment, with Plaintiffs filing a memorandum of points and authorities in support of the motion. Either Party may file a memorandum addressing any objection to the Settlement that has been submitted. Any request by MCM for entry of the Final Judgment which includes Approval Order and Judgment, or failure to object to Plaintiffs’ request for entry of the following provisionsFinal Approval Order and Judgment, shall not be an admission or concession by MCM as to any matter pertaining to Plaintiffs’ claims or the Action. f. At the Final Approval Hearing, the Court will consider and determine whether the provisions of this Agreement should be finally approved as fair, reasonable, and adequate, whether any objections to the Agreement should be overruled, whether the requested Fee Award and the requested Incentive Awards should be approved, and whether a judgment finally approving the Settlement Agreement should be entered. g. This Settlement Agreement is subject to and conditioned upon the issuance by the Court of a Final Approval Order that grants final approval of this Agreement and: a. A finding (i) finds that the Notice Program fully provided satisfies the requirements of Rule 23 of the Massachusetts Rules of Civil Procedure and accurately informed all due process under the Constitution of the United States; (ii) finds that Settlement Class Members entitled to notice of have been adequately represented by the material elements of Class Representatives and Class Counsel; (iii) finds that the SettlementSettlement Agreement is fair, constitutes the best notice practicable under the circumstances, constitutes valid, duereasonable, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and any other applicable law; b. A finding that after proper notice adequate to the Settlement Class, that each Settlement Class Member shall be bound by this Agreement, including the releases in Section V, and after sufficient opportunity to object, no timely objections to that this Settlement Agreement have been made, or a finding that all timely objections have been considered should be and deniedis approved; c. Approval of (iv) dismisses on the Settlement, as set forth in the Settlement Agreement, as fair, reasonable, adequate, merits and in the best interests with prejudice all claims of the Settlement Class, in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability by any of the Parties, or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shallasserted against MCM, without fees or costs to any Party except as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claimsprovided in this Agreement; and h. A reservation (v) retains jurisdiction of exclusive and continuing jurisdiction over all matters relating to the lawsuit and the Parties for the purposes ofinterpretation, among other thingsadministration, (i) supervising the implementation, enforcement, constructioneffectuation, and interpretation enforcement of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable lawthis Settlement. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.

Final Approval Hearing. 72. The Parties Court will recommend that the hold a Final Approval Hearing shall be scheduled no earlier than one hundred on [INSERT DATE] to consider whether to approve the Settlement (100) Days after including the Notice Date. 73. The Parties may file a response Application for Attorneys’ Fees and Expenses up to any Objections $[AMOUNT] of the Settlement Sum and a Motion for Final Approval no later than fourteen (14) Days prior service award of $[AMOUNT] to Plaintiff, all of which are to be paid from the Final Approval Hearing. 74Settlement Sum). Any Settlement Class Member who wishes to You may appear at the Final Approval Hearing through counsel must, by the Objection Deadlinehearing, either mail yourself or hand-deliver through an Attorney you hire, but you do not have to the Court do so. If you intend to appear, either yourself or through an attorney you hire, you must file and serve a notice of appearance in intention to appear satisfying the lawsuit, and take all other actions or make any additional submissions as may be required by this Settlement Agreement, or as otherwise ordered by the Court. 75. Plaintiffs shall ask the Court to enter a Final Approval Order and Final Judgment which includes the following provisions: a. A finding that the Notice Program fully and accurately informed all Settlement Class Members entitled to notice of the material elements of the Settlement, constitutes the best notice practicable under the circumstances, constitutes valid, due, and sufficient notice, and complies fully with the laws of Florida, the United States Constitution, and any other applicable law; b. A finding that after proper notice to the Settlement Class, and after sufficient opportunity to object, no timely objections to this Settlement Agreement have been made, or a finding that all timely objections have been considered and denied; c. Approval of the Settlement, as requirements set forth in the Settlement AgreementAgreement and detailed in the Long Form Notice. For more information, call [INSERT PHONE NUMBER] or visit the Settlement Website [INSERT WEBSITE URL]. A settlement has been reached in the class action lawsuit listed above. In the lawsuit Plaintiff, ▇▇▇▇▇▇▇ ▇▇▇▇▇▇ (“Plaintiff”), alleges that CVS had to recall CVS store brand over-the-counter eyedrop products (the “Products”) after the U.S. Food and Drug Administration (FDA)’s investigators found unsanitary conditions in a manufacturing facility in India. The company that operates the manufacturing facility in question sold the eyedrops to CVS and other major retailers in the United States. CVS does not concede the truth of any claims against it, denies that the Products were defective in any way, and denies that it did anything wrong. The Court has not decided who is right. Instead, the parties have agreed to a compromise through a settlement (the “Settlement”), as fair, reasonable, adequate, and reflected in the best interests terms of the [INSERT DATE], 2025 Settlement Agreement (the “Settlement Agreement”) executed by the parties. The Settlement offers payments to Settlement Class Members who file Valid Claims (“Cash Awards,” as defined below). Your legal rights will be affected even if you do not act. Your rights and options — and the deadlines to exercise them — are explained in this Class Notice. Please read this Notice carefully in its entirety. Defined terms have the meanings given to them in the Settlement Agreement. SETTLEMENT CLASS MEMBERS’ LEGAL RIGHTS AND OPTIONS IN THE SETTLEMENT DO NOTHING If you are a Settlement Class Member and do not take any action, you will not receive any Cash Award under the Settlement. Further, if the Settlement is finally approved, you will be bound by the Court’s final judgment and the release of claims explained in the Settlement Agreement. None SUBMIT A CLAIM FORM If you are a member of the Settlement Class, you must submit a Valid Claim, choosing between the two claim options detailed in all respects, finding that the Settlement is in good faith, and ordering the Parties and Settlement Administrator to perform the Settlement in accordance with the terms of this Settlement Agreement; d. A finding that neither the Final Judgment, the Settlement, nor the Settlement Agreement shall constitute an admission of liability and herein, to receive a Cash Award. If the Court approves the Settlement and it becomes final and effective, and you remain in the Settlement Class, you will receive your Cash Award by any check or electronic payment. To find out how to submit a Claim Form, please read Question 11. Received on or before [INSERT DATE] [60 days after Notice Date] EXCLUDE YOURSELF (OPT OUT) If you choose to opt out, you will receive no benefits from the Settlement. Requesting exclusion from the Settlement (also called “opting out”) would allow you to file or continue your own lawsuit against CVS about the legal claims involved in the Settlement. To find out how to opt out, please read Question 13. Received on or before [INSERT DATE] [60 days after Notice Date] OBJECT OR COMMENT Write to the Court about why you do or do not like the Settlement. To find out how to object or comment, please read Question 15. Filed and served on or before [INSERT DATE] [60 days after Notice Date] GO TO FINAL APPROVAL HEARING Ask to speak in court about the fairness of the PartiesSettlement. To find out how to do so, please read Question 18. Filed and served on or any liability or wrongdoing whatsoever by any Party; e. Subject to the reservation of jurisdiction for matters discussed in subparagraph (h) below, a dismissal with prejudice of the lawsuit; f. A finding that Plaintiffs shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Plaintiffs’ Released Claims; g. A finding that all Settlement Class Members who did not validly and timely opt out of the Settlement shall, as of the entry of the Final Judgment, conclusively be deemed to have fully, finally, and forever completely released, relinquished, and discharged the Released Parties from the Released Class Claims; and h. A reservation of exclusive and continuing jurisdiction over the lawsuit and the Parties for the purposes of, among other things, (i) supervising the implementation, enforcement, construction, and interpretation of the Settlement Agreement, the Final Approval Order, and the Final Judgment; and (ii) supervising the administration and distribution of the relief to the Settlement Class and resolving any disputes that may arise with regard to the foregoing. The Court’s exclusive and continuing jurisdiction over the lawsuit and Parties shall include, without limitation, the Court’s power to enforce the bar against Settlement Class Members’ prosecution of Released Claims against Released Parties pursuant to any applicable law. 76. Upon entry of the Final Approval Order, the lawsuit shall be dismissed with prejudice, with the Parties to bear their own attorneys’ fees, costs, and expenses not otherwise awarded in accordance with this Settlement Agreement.before [INSERT DATE] [60 daysafter Notice Date]