Intervention in the U. S. Litigation (1) In the event that the Settling Defendants receive notice of further depositions of their current or former employees in the U.S. Litigation, the Settling Defendants will notify the Electrolytic Plaintiffs of the dates of these depositions being scheduled. The Settling Defendants and other Releasees shall not oppose any application that may be brought by or on behalf of the Electrolytic Plaintiffs to intervene in the U.S. Litigation solely in order to gain access to discovery, depositions, documents and other Documents and information subject to a protective order that are relevant to the Electrolytic Proceedings and is not otherwise inconsistent with the terms of this Settlement Agreement, including subsection 4.1(11). However it is understood and agreed that neither the Settling Defendants nor the other Releasees have any obligation to bring or otherwise participate in such an application.
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Sources: Class Action Settlement Agreement, Class Action Settlement Agreement