Common use of Motion for Final Approval and Entry of Final Judgment Clause in Contracts

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for Final Approval of this Agreement by the Court. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement as being a fair, reasonable, and adequate settlement for the Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing the Action with prejudice; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementApproval, Class Plaintiffsthen DPPs, through Plaintiffs’ Counsel, shall, Co-Lead Class Counsel – in accordance with the schedule set forth in the Court’s Preliminary Approval Order, – shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Co-Lead Class Counsel to Seaboard for its review. To the extent that Seaboard objects to any aspect of the motion, it shall communicate such objection to Co- Lead Class Counsel, and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Certified Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23Procedure, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing Determining that the Action with prejudiceClass Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Actions with prejudice as to Seaboard in all claims against class action complaints asserted by DPPs or the non-existing corporate entity “Inmate Telephone Service” with prejudice.Certified Class; d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing Seaboard Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Requiring Co-Lead Class Plaintiffs and Counsel to file with the Court a list of potential Certified Class Members members that timely excluded themselves from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released ClaimsCertified Class; f. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties Seaboard shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the SettlementSettlement Agreement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreement(A) After Class Notice is issued, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit and prior to the Court Fairness Hearing, Interim Co-Lead Counsel shall file a separate motion for entry of a Final Approval of this Agreement by the Court. The motion for Final Approval shall seek entry of an order Order and Final Judgment: a. Finally approving (i) finally certifying solely for settlement purposes the Settlement Class as defined in Section 1(E) herein; (ii) finding that the Class Notice constituted the best notice practicable under the circumstances and complied in all respects with the requirements of Rule 23 of the Federal Rules of Civil Procedure and due process; (iii) finally approving this Settlement Agreement and its terms as being a fair, reasonable, reasonable and adequate settlement for of the Class within Settlement Class’ claims under Rule 23 of the meaning of Federal Rules of Civil Procedure 23Procedure; (iv) directing that, as to the DB Released Parties, the Action be dismissed with prejudice and directing without costs as against the implementation, performance Settling Class Members; (v) discharging and consummation of releasing the Settlement DB Released Claims as to the DB Released Parties; (vi) determining pursuant to the terms and conditions set forth in this Agreement; b. Dismissing the Action with prejudice; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as shall be Final and appealable; (vii) reserving the Court’s continuing and exclusive jurisdiction over the Settlement and this Agreement, including the administration and consummation of this Agreement; and (viii) containing such other and further provisions consistent with the terms of this Agreement to which Deutsche Bank and Representative Plaintiffs expressly consent in writing. (B) Prior to the Released Parties shall be final Fairness Hearing, as provided in Section 5, Interim Co-Lead Counsel will timely request by separate motion that the Court approve its Fee and appealable and entered forthwithExpense Application. The Parties shall take all reasonable steps to obtain Final Approval Fee and Expense Application and the Distribution Plan (as defined in Section 1(N)) are matters separate and apart from the Settlement between the Parties. If the Fee and Expense Application or the Distribution Plan are not approved, in whole or in part, it will have no effect on the finality of the Settlementjudgment.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand certifies the Settlement Class, Class Plaintiffsthen DPPs, through Plaintiffs’ Counsel, shall, Interim Co-Lead Counsel — in accordance with the schedule set forth in the Court’s Preliminary Approval Order, — shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim Co-Lead Counsel to JBS for their review. To the extent that JBS objects to any aspect of the motion, it shall communicate such objection to Interim Co-Lead Counsel and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules Rule of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the this Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing Determining that the Action with prejudiceClass Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Actions with prejudice as to JBS in all claims against class action complaints asserted by DPPs or the non-existing corporate entity “Inmate Telephone Service” with prejudice.Settlement Class; d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. f. Determining under Fed. R. Civ. P. Federal Rule of Civil Procedure 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties JBS shall be final and appealable and entered forthwith. The Parties shall act in good faith to support and take all reasonable steps necessary to obtain Final Approval of the SettlementSettlement Agreement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand the Settlement Class shall submit, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s and Settling Defendant shall assent to and assist as Preliminary Approval Order, submit to the Court a separate motion for . The Final Approval of this Agreement by the Court. The motion for Final Approval Motion shall seek entry of an order and Final Judgmentfinal ttling Defendant shall have the opportunity to review and approve before it is submitted to the Court: a. Finally approving the Finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Settling Plaintiffs and the Settlement Class within the meaning of Fed. R. Civ. P. 23 and directing its consummation pursuant to its terms; b. Finding that Notice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation Procedure; c. Finding that all members of the Settlement pursuant Class who have not executed timely and valid or otherwise Court-approved requests for exclusion shall be bound by this Settlement Agreement, including the release provisions and covenant not to the terms and conditions sue set forth in this Settlement Agreement; b. Dismissing d. Incorporating the Action with prejudice; c. Dismissing all claims against releases set forth in Paragraphs 12 and 13, below, and forever barring the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and Releasors (as defined in Paragraph 12) from all further liability to Plaintiffs and Class Members with respect to the asserting any Released Claims (but not as to defined in Paragraph 12) against any obligations created or owed pursuant to this Agreement)of the Releasees as defined below; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and Retaining exclusive jurisdiction over the Settlement and this Settlement Agreement, including the administration and consummation of this Settlement; f. Directing that all claims by and on behalf of the Settling Plaintiffs and the Settlement Class be dismissed with prejudice as to Releasees only and, except as provided for all purposes; herein, with prejudice and without and g. Determining under pursuant to Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal Final Approval Order in the Action as to the Released Parties Releasees shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementimmediately appealable.

Motion for Final Approval and Entry of Final Judgment. If Not less than thirty-five (35) calendar days prior to the date set by the Court grants Preliminary Approval of to hold a fairness hearing to consider whether this AgreementSettlement should be finally approved, Class Plaintiffs, through Plaintiffs’ Counsel, shallPlaintiffs shall submit, in accordance consultation with Settling Defendants, and the schedule set forth in the Court’s Preliminary Approval OrderSettling Defendants shall not object to, submit to the Court a separate motion Motion for Final Approval of this Agreement the Settlement by the Court. The motion for Final Approval shall seek entry of an order and Final Judgment, seeking the following: a. Finally Fully and finally approving the this Settlement Agreement and its terms as being a fair, reasonable, and adequate settlement for as to the Settlement Class within the meaning of Rule 23(e) of the Federal Rules of Civil Procedure and directing its consummation according to its terms and conditions; b. Finding that the notice given to the Settlement Class constitutes the best notice practicable under the circumstances and complies in all respects with the due, adequate, and sufficient notice requirements of Federal Rule of Civil Procedure 23, and directing meets the implementation, performance and consummation requirements of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing the Action with prejudicedue process; c. Dismissing Directing that, as to the Settling Defendants, the Action and all claims against the non-existing corporate entity “Inmate Telephone Service” therein be dismissed with prejudice.prejudice and, except as provided for in this Settlement Agreement, without costs; d. Ordering Discharging and releasing the Class Plaintiffs and Class Members to discharge Releasees from the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining the institution and prosecution, by any Settlement Class Plaintiffs and Class Members from bringingMember, filing, commencing, prosecuting (or further prosecuting), or intervening in, of any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts against the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity Releasees based on the Released Claims; f. Reserving continuing and exclusive jurisdiction over the settlement and this Settlement Agreement, including all future proceedings concerning the administration, interpretation, consummation, and enforcement of this settlement, to the United States District Court for all purposes; andthe Southern District of Ohio; g. Determining Finding under Fed. R. Civ. P. Rule 54(b) of the Federal Rules of Civil Procedure that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties Settling Defendants shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps ; and h. Requiring Plaintiffs’ Counsel to obtain Final Approval file with the Clerk of the SettlementCourt under seal a record with the names and addresses of individuals who timely opt out of the Settlement Class and to provide a copy of the record to Settling Defendants’ Counsel. No later than five (5) business days after the Court fully and finally approves this Settlement Agreement and its terms, Plaintiffs shall seek entry of Final Judgment as to the Settling Defendants.

Motion for Final Approval and Entry of Final Judgment. If Not less than thirty-five (35) calendar days before the date set by the Court grants Preliminary Approval of to hold a fairness hearing to consider whether this AgreementSettlement should be finally approved, Class Plaintiffs, through Plaintiffs’ Counsel, shallRepresentatives shall submit, in accordance consultation with the schedule set forth in the Court’s Preliminary Approval OrderDefendants, submit to the Court a separate motion Motion for Final Approval of this Agreement by the CourtSettlement. The motion Defendants shall not object to a Motion for Final Approval shall seek entry of an order and Final Judgmentthe Settlement by the Court seeking the following: a. Finally Fully and finally approving the this Settlement Agreement and its terms as being a fair, reasonable, and adequate settlement for as to the Class Settlement Classes within the meaning of Rule 23(e) of the Federal Rules of Civil Procedure and directing its consummation according to its terms and conditions; b. Finding that the notice given to the Settlement Classes constitutes the best notice practicable under the circumstances and complies in all respects with the due, adequate, and sufficient notice requirements of Federal Rule of Civil Procedure 23, and directing meets the implementation, performance and consummation requirements of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing the Action with prejudicedue process; c. Dismissing Directing that the Action and all claims against the non-existing corporate entity “Inmate Telephone Service” therein be dismissed with prejudice.prejudice and, except as provided for in this Settlement Agreement, without costs; d. Ordering Discharging and releasing the Class Plaintiffs and Class Members to discharge Releasees from the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining the institution and prosecution, by any Settlement Class Plaintiffs and Class Members from bringingMember, filing, commencing, prosecuting (or further prosecuting), or intervening in, of any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts against the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity Releasees based on the Released Claims; f. Reserving continuing and exclusive jurisdiction over the settlement and this Settlement Agreement, including all future proceedings concerning the administration, interpretation, consummation, and enforcement of this settlement, to the United States District Court for all purposes; andthe Western District of Tennessee; g. Determining Finding under Fed. R. Civ. P. Rule 54(b) of the Federal Rules of Civil Procedure that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties Defendants shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps ; and h. Requiring Class Counsel to obtain Final Approval file with the Clerk of the SettlementCourt under seal a record with the names and addresses of individuals who timely opt out of the Settlement Classes and to provide a copy of the record to Defendants’ Counsel. No later than five (5) business days after the Court fully and finally approves this Settlement Agreement and its terms, Plaintiffs shall seek entry of Final Judgment of the Action.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval preliminarily approves this Settlement Agreement, Plaintiffs shall submit – and Defendants shall support – a motion for final approval by the Court of this Agreement, Settlement Agreement (“Final Approval Motion”) after notice has been disseminated to the Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with pursuant to the schedule set forth in the Court’s Preliminary Approval Order, submit . The Final Approval Motion shall be submitted to the Court a separate motion for Final Approval of this Agreement by within twenty-one (21) days after the Court. The motion for Final Approval -ordered deadline by which members of the Class may exclude themselves from the Class or object to the Settlement, and shall seek entry of an order and final judgment (“Final Judgment:Approval Order”): a. Finally approving the (a) finding this Settlement as being Agreement and its terms to be a fair, reasonable, reasonable and adequate settlement for as to Plaintiffs and the Direct Purchaser Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23, and directing the implementation, performance and its consummation of the Settlement pursuant to its terms; (b) finding that all Class Members shall be bound by this Agreement, including the terms release provisions and conditions covenant not to ▇▇▇ set forth in this Agreement; b. Dismissing (c) finding that notice given constitutes due, adequate and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure; (d) incorporating the release set forth in Paragraphs 11 and 12 of this Agreement, and forever barring the Releasors from asserting any claims or liabilities related to the Action with prejudiceor any Released Claims against any of the Releasees as defined below; c. Dismissing all claims against (e) providing for the nonpayment of reasonable attorneys’ fees and reimbursement of expenses from the Settlement Fund as described herein, based upon a motion seeking such fees filed sufficiently in advance of the Court-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering ordered deadline before which members of the Class Plaintiffs and may exclude themselves from the Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect or object to the Released Claims Settlement; (but not f) providing for service awards from the Settlement Fund in the amount of $50,000 each to Meijer, RDC, and ASC (the “Named Plaintiffs”) in addition to whatever monies each may receive from the Settlement Fund pursuant to a Court-approved Plan of Allocation; (g) directing that the Direct Purchaser Class Action be dismissed with prejudice as to any obligations created or owed pursuant to this Agreement)Defendants and, except as provided for herein, without costs; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause h) determining that under Federal Rule of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining under Fed. R. Civ. P. Civil Procedure 54(b) that there is no just reason for delay and directing that the judgment of dismissal with prejudice as to the Released Parties Defendants shall be final final; (i) retaining exclusive jurisdiction over the Settlement and appealable the Settlement Agreement, including the administration and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval consummation of the Settlement; and (j) directing that, for a period of five years, the Clerk of the Court shall maintain the record of those members of the Class who have timely excluded themselves from the Direct Purchaser Class (“Opt-Outs”) and that a certified copy of such records shall be provided to Defendants.

Motion for Final Approval and Entry of Final Judgment. If the District Court grants Preliminary Approval certifies the Direct Purchaser Class for purposes of settlement and preliminarily approves this Settlement Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, Plaintiffs shall submit to the Court a separate motion for Final Approval final approval of this the Settlement Agreement by the District Court. The motion for Final Approval , after appropriate notice to the Class, and shall seek entry of an a final judgment and order (the “Final Judgment and Order”). The Final JudgmentJudgement and Order shall: a. Finally approving find that this Settlement Agreement and the terms of the Settlement as being a are fair, reasonable, and adequate settlement for as to Plaintiffs and the Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23, and directing the implementation, performance and direct its consummation of the Settlement pursuant to the terms and conditions set forth in of this Settlement Agreement; b. Dismissing provide for payment of reasonable attorneys’ fees and reimbursement of costs and expenses from the Action with prejudiceSettlement Fund (as defined below) as described herein; c. Dismissing all claims against provide for payment from the nonSettlement Fund of service awards to each of the named Plaintiffs, in addition to whatever monies they will receive from the Settlement Fund pursuant to a District Court-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering approved plan of allocation to the Class Plaintiffs and Class Members to discharge (the Released Parties “Plan of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this AgreementAllocation”); e. Permanently barring d. direct that Plaintiffs’ and enjoining Direct Purchaser Class Plaintiffs members’ claims against Pfizer be dismissed with prejudice and, except as provided for in paragraph 11, without costs and Class Members from bringing, filing, commencing, prosecuting (or further prosecutingwithout attorney’s fees recoverable under 15 U.S.C. § 15(a), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claimsexcept as otherwise provided for herein; f. Reserving continuing and e. retain exclusive jurisdiction over the Settlement for all purposesand this Settlement Agreement, including the administration and consummation of this Settlement; and g. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing f. direct that the judgment of dismissal as to the Released Parties of all Class claims against Pfizer shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementappealable.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementAgreement and certifies the Direct Purchaser Settlement Class, Direct Purchaser Class Plaintiffs, through Plaintiffs’ Interim DPP Lead Counsel, shall, —in accordance with the schedule set forth in the Court’s Preliminary Approval Order, Approval—submit to the Court a separate motion for Final Approval of this Agreement by the Court, the text of which shall be proposed by Interim DPP Lead Counsel, subject to the agreement of SII, which agreement shall not be unreasonably withheld. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally finally approving the Settlement as being a fair, reasonable, and adequate settlement for the Direct Purchaser Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing dismissing the Action Direct Purchaser Class Action, with prejudiceprejudice as to the SII Released Parties; c. Dismissing discharging and releasing the SII Released Parties from all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice.Released Claims; d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining e. determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the SII Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.

Motion for Final Approval and Entry of Final Judgment. If (A) After Class Notice is issued, and at least thirty-five (35) calendar days prior to the Court grants Preliminary Approval of this AgreementFairness Hearing, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit Lead Counsel shall make a motion to the Court a separate motion for the final approval of the Settlement and seeking entry of the Final Approval of this Agreement by Order and Judgment on substantially the Court. The motion for Final Approval shall seek entry of an order and Final Judgmentfollowing terms: a. Finally approving (i) finally certifying, solely for settlement purposes, the Settlement Class as defined in Section 2 herein; (ii) finding that the Class Notice constituted the best notice practicable under the circumstances and complied in all respects with the requirements of Rule 23 of the Federal Rules of Civil Procedure and due process; (iii) fully and finally approving this Settlement Agreement and its terms as being a fair, reasonable, and adequate settlement for of the Class within Settlement Class’s claims under Rule 23 of the meaning of Federal Rules of Civil Procedure 23Procedure, and directing the implementation, performance and its consummation of the Settlement pursuant to the its terms and conditions set forth in this Agreementconditions; b. Dismissing (iv) directing that the Action be dismissed in its entirety and with prejudiceprejudice as to Settling Defendants and the Releasees, without costs; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs (v) discharging and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to releasing the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)the Releasees; e. Permanently (vi) permanently barring and enjoining the institution and prosecution by Exchange-Based Plaintiffs, Releasors, and any Settlement Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, Member of any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts against the Released Claims or receiving any settlement consideration Releasees in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause jurisdiction asserting any of action in law or equity based on the Released Claims; f. Reserving continuing and exclusive jurisdiction over (vii) barring claims by any Person against the Settlement Releasees for contribution, indemnification, or similar claims (however denominated) for all purposes; andor a portion of any amounts paid or awarded in the Action by way of settlement, judgment, or otherwise; g. Determining under Fed. R. Civ. P. (viii) determining pursuant to Federal Rule 54(b) that there is no just reason for delay and directing entry of a final Judgment dismissing with prejudice all claims in the Action as to Settling Defendants; (ix) reserving the Court’s continuing and exclusive jurisdiction over the Settlement Agreement, including all future proceedings concerning the administration, consummation, and enforcement of this Agreement; and (x) containing such other and further provisions consistent with the terms of this Agreement to which Settling Defendants and Exchange-Based Plaintiffs expressly consent in writing. (B) At least thirty-five (35) calendar days prior to the Fairness Hearing, as provided in Section 4(D), Exchange-Based Plaintiffs’ Counsel will timely request by separate motion that the judgment of dismissal as to the Released Parties shall be final Court approve its Fee and appealable and entered forthwithExpense Application. The Parties shall take all reasonable steps Fee and Expense Application (as defined in Section 1(Q)) and the Distribution Plan (as defined in Section 1(J)) are matters separate and apart from the Settlement Agreement between the Parties. If the Fee and Expense Application, any application for service awards to obtain Final Approval any Exchange-Based Plaintiff, or the Distribution Plan are not approved, in whole or in part, such disapproval will have no effect on the finality of the SettlementJudgment.

Motion for Final Approval and Entry of Final Judgment. If Prior to the date set by the Court grants Preliminary Approval of to consider whether this AgreementSettlement should be finally approved, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, Counsel shall submit to the Court a separate motion for Final Approval final approval of this Agreement the Settlement by the Court. The motion for Final Approval Settling Parties shall jointly seek entry of an order the Final Approval Order and Final Judgment: a. Finally (a) certifying the Settlement Class, as defined in this Settlement Agreement, pursuant to Federal Rule of Civil Procedure 23, solely for purposes of this Settlement; (b) fully and finally approving the Settlement contemplated by this Settlement Agreement and its terms as being a fair, reasonable, reasonable and adequate settlement for the Class within the meaning of Federal Rules Rule of Civil Procedure 23, 23 and directing the implementation, performance and its consummation of the Settlement pursuant to the its terms and conditions set forth conditions. (c) finding that the notice given to the Class Members constituted the best notice practicable under the circumstances and complies in this Agreementall respects with the requirements of Federal Rule of Civil Procedure 23 and due process; b. Dismissing (d) directing that the Action be dismissed with prejudiceprejudice as to Shinyei and, except as provided for herein, without costs; c. Dismissing (e) discharging and releasing the Releasees from all claims against Released Claims; (f) permanently barring and enjoining the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class institution and prosecution, by Indirect Purchaser Plaintiffs and Class Members to discharge Members, of any other action against the Released Parties of and from all further liability to Plaintiffs and Class Members with respect Releasees in any court asserting any claims related in any way to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving g) reserving continuing and exclusive jurisdiction over the Settlement, including all future proceedings concerning the administration, consummation and enforcement of this Settlement for all purposesAgreement; andLAW OFFICES COTCHETT, ▇▇▇▇▇ & g. Determining under Fed. R. Civ. P. (h) determining pursuant to Federal Rule of Civil Procedure 54(b) that there is no just reason for delay and directing that the entry of a final judgment of dismissal as to ▇▇▇▇▇▇▇; and (i) containing such other and further provisions consistent with the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps terms of this Settlement Agreement to obtain Final Approval of which the Settlementparties expressly consent in writing.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval preliminarily approves this Settlement, Plaintiffs and the Direct Purchaser Class shall submit and Shire shall support a motion for final approval of this AgreementSettlement by the Court (the “Final Approval Motion”), after Notice has been disseminated to the Direct Purchaser Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with pursuant to the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for . The Final Approval of this Agreement by the Court. The motion for Final Approval Motion shall seek entry of an order and final judgment (“Final Judgment:Approval Order”) substantially in the form of Exhibit C hereto a. Finally approving the Finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Plaintiffs and the Direct Purchaser Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing the Action with prejudice; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay 23 and directing its consummation pursuant to its terms; b. Finding that notice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure; c. Finding that the judgment proposed Plan of dismissal Allocation, which allocates the Settlement Fund (net of Court-approved attorney fees, expenses, and settlement administration costs) pro rata based on the number of tablets of brand and/or generic Intuniv purchased during the relevant period (net of returns) by each member of the Direct Purchaser Class, is fair and efficient. d. Finding that all members of the Direct Purchaser Class shall be bound by this Settlement Agreement, including the release provisions and covenant not to sue set forth in this Settlement Agreement; e. Incorporating the releases set forth in Paragraphs 9 and 10, below, and forever barring the Releasors from asserting any Released Claims against any of the Releasees as defined below; f. Providing for an award of reasonable attorneys’ fees and reimbursement of expenses solely from the Settlement Fund; g. Retaining exclusive jurisdiction over the Settlement and this Settlement Agreement, including the administration and consummation of this Settlement; h. Directing that all claims by and on behalf of Plaintiff and the Direct Purchaser Class be dismissed with prejudice as to the Released Parties shall be final Shire only and, except as provided for herein, with prejudice and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.without costs or attorney’s fees recoverable under 15 U.S.C. § 15(a); and

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval preliminarily approves this Settlement, Plaintiffs and the Direct Purchaser Classes shall submit, and Ranbaxy shall support, a motion for final approval of this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with Settlement by the schedule set forth in Court (the Court’s “Final Approval Motion”) within sixty (60) days after the Court enters the Preliminary Approval Order, submit and after notice has been disseminated to the Court a separate motion for Direct Purchaser Classes pursuant to the Preliminary Approval Order. The Final Approval of this Agreement by the Court. The motion for Final Approval Motion shall seek entry of an order and final judgment (“Final Judgment:Approval Order”) substantially in the form of Exhibit C hereto— a. Finally approving the a) finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Plaintiffs and the Class Direct Purchaser Classes within the meaning of Federal Rule of Civil Procedure 23 and directing its implementation pursuant to its terms; b) finding that the notice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure 23Procedure; c) finding that the proposed allocation plan, which allocates the Settlement Fund (net of Court-approved attorneys’ fees, expenses, and directing settlement administration costs), is fair and efficient; d) finding that all Class Members shall be bound by this Settlement Agreement, including the implementation, performance release provisions and consummation of the Settlement pursuant covenant not to the terms and conditions sue set forth in this Settlement Agreement; b. Dismissing e) incorporating the Action with prejudice; c. Dismissing all claims against releases set forth in Paragraphs 8 and 9, below, and forever barring the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and Plaintiff Releasors (as defined below) from all further liability to Plaintiffs and Class Members with respect to the asserting any Released Claims (but not as to defined below) against any obligations created or owed pursuant to this Agreementof the Ranbaxy Releasees (as defined below); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and f) retaining exclusive jurisdiction over the Settlement and this Settlement Agreement, including the administration and implementation of this Settlement; g) directing that all claims by and on behalf of Plaintiffs and the Direct Purchaser Classes be dismissed with prejudice as to Ranbaxy and, except as provided for all purposesherein, with prejudice and without costs or attorneys’ fees recoverable under 15 U.S.C. § 15(a); and g. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand preliminarily certifies the Settlement Class, Class Plaintiffsthen DPPs, through Plaintiffs’ Counsel, shall, Interim Co-Lead Counsel — in accordance with the schedule set forth in the Court’s Preliminary Approval Order, — shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim Co-Lead Counsel to Cargill for its review. To the extent that ▇▇▇▇▇▇▇ objects to any aspect of the motion, it shall communicate such objection to Interim Co-Lead Counsel and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in this Agreementconditions, without material modification of those terms and conditions; b. Dismissing Determining that the Action with prejudiceSettlement Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing all claims against complaints asserted by Releasing Parties in the non-existing corporate entity “Inmate Telephone Service” Action with prejudice.prejudice as to ▇▇▇▇▇▇▇ without further costs or fees; d. Ordering Discharging and releasing the ▇▇▇▇▇▇▇ Released Parties from all Released Claims; e. Enjoining the Releasing Parties from suing any of the ▇▇▇▇▇▇▇ Released Parties for any of the Released Claims; f. Filing a declaration prepared by counsel for ▇▇▇▇▇▇▇ confirming that ▇▇▇▇▇▇▇ has provided the appropriate notice pursuant to the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims Action Fairness Act, 28 U.S.C. §1711 et seq. (but not as to any obligations created or owed pursuant to this Agreement“CAFA”); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties ▇▇▇▇▇▇▇ shall be final and appealable and entered forthwith. The Parties shall take use all reasonable steps best efforts to obtain Final Approval of the SettlementSettlement Agreement without modification to any of its material terms and conditions.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand preliminarily certifies the Settlement Class, Class Plaintiffsthen DPPs, through Plaintiffs’ Counsel, shall, Interim Co-Lead Counsel — in accordance with the schedule set forth in the Court’s Preliminary Approval Order, — shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim Co-Lead Counsel to Tyson for its review. To the extent that Tyson objects to any aspect of the motion, it shall communicate such objection to Interim Co-Lead Counsel and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in this Agreementconditions, without material modification of those terms and conditions; b. Determining that the Settlement Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Action with prejudiceprejudice as to Tyson in all class action complaints asserted by DPPs without further costs or fees; c. Dismissing d. Discharging and releasing the Tyson Released Parties from all claims against Released Claims; e. Enjoining DPPs from suing any of the non-existing corporate entity “Inmate Telephone Service” with prejudice.Tyson Released Parties for any of the Released Claims; d. Ordering f. Filing a declaration prepared by counsel for Tyson confirming that Tyson has provided the appropriate notice pursuant to the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims Action ▇▇▇▇▇▇▇▇ ▇▇▇, ▇▇ ▇.▇.▇. §▇▇▇▇ et seq. (but not as to any obligations created or owed pursuant to this Agreement“CAFA”); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties Tyson shall be final and appealable and entered forthwith. The Parties shall take use all reasonable steps best efforts to obtain Final Approval of the SettlementSettlement Agreement without modification to any of its material terms and conditions.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval Approval, preliminarily certifies the Settlement Class, and approves the form and manner of this AgreementSettlement Class Notice, Class then Plaintiffs, through Plaintiffs’ Counsel, Interim Co-Lead Class Counsel shall, in accordance with the schedule set forth in the Court’s Preliminary Approval OrderApproval, submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim Co-Lead Counsel to ▇▇▇▇▇▇▇▇▇ for its review. To the extent that ▇▇▇▇▇▇▇▇▇ objects to any aspect of the motion, it shall communicate such objection to Interim Co-Lead Class Counsel and the Parties shall meet and confer to resolve any such objection in good faith. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in conditions, without material modification of those terms and conditions; b. Determining that the Settlement Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement; b. c. Dismissing the Action with prejudiceprejudice as to ▇▇▇▇▇▇▇▇▇ in all complaints asserted by Plaintiffs without further costs or fees; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing ▇▇▇▇▇▇▇▇▇ Released Parties of and from all further liability to Plaintiffs and Class Members with respect to Released Claims; e. Enjoining the Releasing Parties from asserting, directly or indirectly, any of the Released Claims (but not as to against any obligations created or owed of the ▇▇▇▇▇▇▇▇▇ Released Parties in any forum; f. Confirming that ▇▇▇▇▇▇▇▇▇ has provided the appropriate notice pursuant to this Agreementthe Class Action Fairness Act, 28 U.S.C. § 1711 et seq. (“CAFA”); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties ▇▇▇▇▇▇▇▇▇ shall be final and appealable and entered forthwith. The Parties shall take use all reasonable steps best efforts to obtain Final Approval of the SettlementSettlement Agreement without modification to any of its material terms and conditions.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval preliminarily approves this Settlement, Named Plaintiffs shall submit—and Novartis shall not oppose in any court, including on appeal—a motion for final approval by the Court of this Agreement, Settlement (“Final Approval Motion”) after notice has been disseminated to Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with Members pursuant to the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for . The Final Approval of this Agreement by the Court. The motion for Final Approval Motion shall seek entry of an order and final judgment (“Final JudgmentApproval Order”) substantially in the form attached hereto as Exhibit C: a. Finally approving the finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Named Plaintiffs and the Direct Purchaser Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23, and directing the implementation, performance and its consummation pursuant to its terms; b. finding that all members of the Class (“Class Members”) shall be bound by this Settlement pursuant Agreement, including the release provisions and covenant not to the terms and conditions sue set forth in this Settlement Agreement; b. Dismissing c. finding that the Action with prejudicenotice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure; c. Dismissing d. incorporating the release set forth in Paragraph 11 of this Settlement Agreement, and forever barring the Releasors from asserting any Released Claims against any of the Releasees as defined below; e. providing for the payment of reasonable attorneys’ fees and reimbursement of costs and expenses solely from the Settlement Fund; f. providing for payment solely from the Settlement Fund of service awards in the amount of $100,000 each to the Named Plaintiffs, in addition to whatever monies each may receive from the Settlement Fund pursuant to a Court-approved plan of allocation; g. directing that all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class by and on behalf of Named Plaintiffs and the Direct Purchaser Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members be dismissed with respect to the Released Claims (but not prejudice as to any obligations created Novartis and, except as provided for herein, without costs or owed pursuant to this Agreementattorney’s fees recoverable under 15 U.S.C. § 15(a); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and h. retaining exclusive jurisdiction over the Settlement for all purposesand the Settlement Agreement, including the administration and consummation of the Settlement; and g. Determining under i. directing that the judgment of dismissal with prejudice of all Direct Purchaser Class claims against Novartis shall be final and immediately appealable pursuant to Fed. R. Civ. P. 54(b) that ), there is being no just reason for delay and directing that the judgment of dismissal as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementdelay.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand preliminarily certifies the Settlement Class, Class Plaintiffsthen CIIPPs, through Plaintiffs’ Counsel, shall, Putative Interim Co-Lead Counsel — in accordance with the schedule set forth in the Court’s Preliminary Approval Order, — shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Putative Interim Co- Lead Counsel to Tyson for its review. To the extent that Tyson objects to any aspect of the motion, it shall communicate such objection to Putative Interim Co-Lead Counsel and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in this Agreementconditions, without material modification of those terms and conditions; b. Determining that the Settlement Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Action with prejudiceprejudice as to Tyson in all class action complaints asserted by CIIPPs without further costs or fees; c. Dismissing d. Discharging and releasing the Tyson Released Parties from all claims against Released Claims; e. Enjoining CIIPPs from suing any of the non-existing corporate entity “Inmate Telephone Service” with prejudice.Tyson Released Parties for any of the Released Claims; d. Ordering f. Filing a declaration prepared by counsel for Tyson confirming that Tyson has provided the appropriate notice pursuant to the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims Action Fairness Act, 28 U.S.C. §1711 et seq. (but not as to any obligations created or owed pursuant to this Agreement“CAFA”); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties Tyson shall be final and appealable and entered forthwith. The Parties shall take use all reasonable steps best efforts to obtain Final Approval of the SettlementSettlement Agreement without modification to any of its material terms and conditions.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand certifies the Settlement Class, Class Plaintiffsthen EUCPs, through Plaintiffs’ Lead Counsel, shall, and in accordance with the schedule set forth in the Court’s Preliminary Approval OrderApproval, shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Lead Counsel to ▇▇▇▇ for its review. To the extent that ▇▇▇▇ objects to any aspect of the motion, it shall communicate such objection to Lead Counsel and the parties shall meet and confer about any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in this Agreementconditions, without material modification of those terms and conditions; b. Determining that the Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Action with prejudiceprejudice as to ▇▇▇▇ in all class action complaints asserted by EUCPs, without further costs or fees; c. Dismissing all claims against d. Discharging and releasing the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the ▇▇▇▇ Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Enjoining Plaintiffs and members of the Settlement Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, suing any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the ▇▇▇▇ Released Claims or receiving Parties for any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims; f. Confirming that ▇▇▇▇ has provided the appropriate notice pursuant to the Class Action Fairness Act, 28 U.S.C. 5171 1, et seq. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties ▇▇▇▇ shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand certifies the Settlement Class, Class Plaintiffsthen EUCPs, through Plaintiffs’ Counsel, shall, Lead Counsel — in accordance with the schedule set forth in the Court’s 's Preliminary Approval Order, shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Lead Counsel to Mountaire for its review. To the extent that Mountaire objects to any aspect of the motion, it shall communicate such objection to Lead Counsel and the parties shall meet and confer about any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Determining that the Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Action with prejudiceprejudice as to Mountaire in all class action complaints asserted by EUCPs; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing Mountaire Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring Enjoining EUCPs and enjoining members of the Settlement Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, suing any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Mountaire Released Claims or receiving Parties for any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims; f. Confirming that ▇▇▇▇▇▇▇▇▇ has provided the appropriate notice pursuant to the Class Action Fairness Act, 28 U.S.C. 5171 1, et seq. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties ▇▇▇▇▇▇▇▇▇ shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the SettlementSettlement Agreement.

Motion for Final Approval and Entry of Final Judgment. If In the event the Court grants Preliminary Approval enters an order preliminarily approving the Settlement, the Plaintiffs shall draft a motion for final approval of this Agreementthe Settlement and all necessary supporting documents, Class which Columbia University shall have a right to review and approve (which approval shall not be unreasonably withheld). Columbia University may suggest revisions, which Plaintiffs agree to consider in good faith, as long as Columbia University provides its suggested revisions or comments within seven (7) business days of having received any such document or documents from Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with or other such time as the Settling Parties may agree. Plaintiffs will file the motion for final approval pursuant to the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for Final Approval of this Agreement ordered by the Court. The final approval motion for Final Approval shall seek entry of an order and Final Judgmenta final approval order, including: a. Finally approving a) finding that notice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure; b) finding the Settlement as being a to be fair, reasonable, and adequate settlement for the Class within the meaning of Federal Rules of Civil Procedure 23, Fed. R. Civ. P. 23 and directing the implementation, performance and consummation of the Settlement pursuant to its terms; c) finding that all Class Members shall be bound by the terms Settlement Agreement and conditions all of its terms; d) finding that the Releasors shall be bound by the respective releases set forth in Paragraphs 13 and 14 of this Settlement Agreement, and shall be forever barred from asserting any claims or liabilities against Columbia University covered by the respective Released Claims against any of the Releasees; b. Dismissing e) approving expressly the provisions in Paragraph 7(e) of the Settlement Agreement allowing payment of Settlement Class Counsel fees and expenses before the Effective Date pursuant to the terms of that Paragraph; f) directing that the Action be dismissed with prejudice; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not prejudice as to any obligations created or owed pursuant to this Agreement); e. Permanently barring Columbia University and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposeswithout costs; and g. Determining g) determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal with prejudice as to the Released Parties shall Columbia University be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.final;

Motion for Final Approval and Entry of Final Judgment. If Not less than thirty-five (35) days prior to the date set by the Court grants Preliminary Approval to consider whether this Settlement should be finally approved pursuant to Federal Rule of this AgreementCivil Procedure 23(e)(2), Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with Counsel shall submit a motion for final approval (“Final Approval”) of the schedule set forth in Settlement by the Court’s Preliminary Approval Order, submit to the Court . Class Counsel shall provide Defendant with a separate draft proposed motion for Final Approval of this Agreement the Settlement by the CourtCourt (including any accompanying memorandum) seven days in advance of filing, and shall consider in good faith any concerns or suggestions expressed by Defendant. Class Counsel shall also provide Defendant with draft proposed order or orders, seven days in advance of filing. The motion for Final Approval Settling Parties shall jointly agree on the content of the proposed Judgment and shall jointly seek entry of an the final approval order (“Final Approval Order”) and Final Judgment, subject to ¶ 12: a. Finally fully and finally approving the Settlement contemplated by this Agreement and its terms as being a fair, reasonable, reasonable and adequate settlement for the Class within the meaning of Federal Rules Rule of Civil Procedure 23, 23 and directing the implementation, performance and its consummation of the Settlement pursuant to the its terms and conditions set forth in this Agreementconditions; b. Dismissing finding that the Action notice given to the Class Members constituted the best notice practicable under the circumstances and complies in all respects with prejudicethe requirements of Federal Rule of Civil Procedure 23 and due process; c. Dismissing all claims against directing that the non-existing corporate entity “Inmate Telephone Service” Action be dismissed with prejudice.prejudice as to Defendant and, except as provided for herein, without costs; d. Ordering discharging and releasing the Class Releasees from all Released Claims; e. permanently barring and enjoining the institution and prosecution, by Plaintiffs and Class Members to discharge Members, of any other action against the Released Parties of and from all further liability to Plaintiffs and Class Members with respect Releasees in any court asserting any claims related in any way to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving ▇. ▇▇▇▇▇▇▇▇▇ continuing and exclusive jurisdiction over the Settlement for Settlement, including all purposes; andfuture proceedings concerning the administration, consummation and enforcement of this Agreement; g. Determining under Fed. R. Civ. P. determining pursuant to Federal Rule of Civil Procedure 54(b) that there is no just reason for delay and directing entry of a final judgment as to Defendant; and 9 h. containing such other and further provisions consistent with the terms of this Agreement to which the parties expressly consent in writing. Class Counsel also will request that the judgment Court approve the proposed Distribution Plan and application for attorneys’ fees and reimbursement of dismissal expenses and service awards (as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementdescribed below).

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of preliminarily approves this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with Settlement (the schedule set forth in the Court’s “Preliminary Approval Order”), submit Settling Plaintiffs and the Settlement Class shall submit, and Settling Defendants shall assent to and assist as necessary, a motion for final approval of this Settlement by the Court (the “Final Approval Motion”), after Notice has been disseminated to the Court a separate motion for Settlement Class pursuant to the Preliminary Approval Order. The Final Approval of this Agreement by the Court. The motion for Final Approval Motion shall seek entry of an order and final judgment (“Final JudgmentApproval Order”), which Settling Defendants shall have the opportunity to review and approve before it is submitted to the Court: a. Finally approving the Finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Settling Plaintiffs and the Settlement Class within the meaning of Fed. R. Civ. P. 23 and directing its consummation pursuant to its terms; b. Finding that Notice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation Procedure; c. Finding that all members of the Settlement pursuant Class who have not executed timely and valid or otherwise Court-approved requests for exclusion shall be bound by this Settlement Agreement, including the release provisions and covenant not to the terms and conditions sue set forth in this Settlement Agreement; b. Dismissing d. Incorporating the Action with prejudice; c. Dismissing all claims against releases set forth in Paragraphs 12 and 13, below, and forever barring the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and Releasors (as defined in Paragraph 12) from all further liability to Plaintiffs and Class Members with respect to the asserting any Released Claims (but not as to defined in Paragraph 12) against any obligations created or owed pursuant to this Agreement)of the Releasees as defined below; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and Retaining exclusive jurisdiction over the Settlement and this Settlement Agreement, including the administration and consummation of this Settlement; f. Directing that all claims by and on behalf of the Settling Plaintiffs and the Settlement Class be dismissed with prejudice as to Releasees only and, except as provided for all purposesherein, with prejudice and without costs or attorney’s fees recoverable under 15 U.S.C. § 15(a); and g. Determining under pursuant to Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal Final Approval Order in the Action as to the Released Parties Releasees shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementimmediately appealable.

Motion for Final Approval and Entry of Final Judgment. If In the event the Court grants Preliminary Approval enters an order preliminarily approving the Settlement, the Plaintiffs shall draft a motion for final approval of this Agreementthe Settlement and all necessary supporting documents, Class which ▇▇▇▇▇ ▇▇▇▇▇▇▇ shall have a right to review and approve (which approval shall not be unreasonably withheld). ▇▇▇▇▇ ▇▇▇▇▇▇▇ may suggest revisions, which Plaintiffs agree to consider in good faith, as long as ▇▇▇▇▇ ▇▇▇▇▇▇▇ provides its suggested revisions or comments within seven (7) business days of having received any such document or documents from Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with or other such time as the Settling Parties may agree. Plaintiffs will file the motion for final approval pursuant to the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for Final Approval of this Agreement ordered by the Court. The final approval motion for Final Approval shall seek entry of an order and Final Judgmenta final approval order, including: a. Finally approving a) finding that notice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure; b) finding the Settlement as being a to be fair, reasonable, and adequate settlement for the Class within the meaning of Federal Rules of Civil Procedure 23, Fed. R. Civ. P. 23 and directing the implementation, performance and consummation of the Settlement pursuant to its terms; c) finding that all Class Members shall be bound by the terms Settlement Agreement and conditions all of its terms; d) finding that the Releasors shall be bound by the respective releases set forth in Paragraphs 13 and 14 of this Settlement Agreement, and shall be forever barred from asserting any claims or liabilities against ▇▇▇▇▇ ▇▇▇▇▇▇▇ covered by the respective Released Claims against any of the Releasees; b. Dismissing e) approving expressly the provisions in Paragraph 7(e) of the Settlement Agreement allowing payment of Settlement Class Counsel fee and expenses before the Effective Date pursuant to the terms of that paragraph; f) directing that the Action be dismissed with prejudiceprejudice as to ▇▇▇▇▇ ▇▇▇▇▇▇▇ and without costs; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining g) determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal with prejudice as to ▇▇▇▇▇ ▇▇▇▇▇▇▇ be final; h) retaining exclusive jurisdiction over the Released Parties shall be final Settlement, including the administration and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval consummation of the Settlement; and i) directing that, for a period of five years, the Clerk of the Court shall maintain the record of the entities that have excluded themselves from the Class and that a certified copy of such records shall be provided to ▇▇▇▇▇ ▇▇▇▇▇▇▇.

Motion for Final Approval and Entry of Final Judgment. If Not less than thirty- five (35) days prior to the date set by the Court grants Preliminary Approval of to consider whether this AgreementSettlement should be finally approved, Class PlaintiffsPlaintiffs shall submit, through Plaintiffs’ Counseland Hitachi Chemical shall not object to, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion Motion for Final Approval of this Agreement the Settlement by the Court. The motion for Final Approval shall seek entry of an order and Final Judgment, seeking the following: a. Finally approving Certifying the Settlement Class, pursuant to Federal Rule of Civil Procedure 23, solely for purposes of settlement; b. Fully and finally approving this Settlement Agreement and its terms as being a fair, reasonable, and adequate settlement for as to the Settlement Class Members within the meaning of Rule 23(e) of the Federal Rules of Civil Procedure and directing its consummation according to its terms and conditions; c. Finding that the notice given to Settlement Class Members constitutes the best notice practicable under the circumstances and complies in all due respects with the due, adequate and sufficient notice requirements of Federal Rule of Civil Procedure 23, and directing meets the implementationrequirements of due process; d. Directing that, performance and consummation of as to Hitachi Chemical, the Settlement pursuant to the terms and conditions set forth Action be dismissed with prejudice and, except as provided for in this Settlement Agreement; b. Dismissing the Action with prejudice; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement), without costs; e. Discharging and releasing the Releasees from the Released Claims; f. Permanently barring and enjoining Class the institution and prosecution, by Direct Purchaser Plaintiffs and Settlement Class Members from bringingMembers, filing, commencing, prosecuting (or further prosecuting), or intervening in, of any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts against the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity Releasees based on the Released Claims; f. g. Reserving continuing and exclusive jurisdiction over the Settlement for and this Settlement Agreement, including all purposesfuture proceedings concerning the administration, interpretation, consummation, and enforcement of this settlement, to the District Court; and g. Determining h. Finding under Fed. R. Civ. P. Federal Rule of Civil Procedure 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties Hitachi Chemical shall be final and appealable and entered forthwith. The Parties In conjunction with or promptly after the Court fully and finally approves this Settlement Agreement and its terms, Plaintiffs shall take all reasonable steps seek entry of Final Judgment as to obtain Final Approval of the SettlementHitachi Chemical.

Motion for Final Approval and Entry of Final Judgment. If In the event the Court grants Preliminary Approval enters an order preliminarily approving the Settlement, the Plaintiffs shall draft a motion for final approval of this Agreementthe Settlement and all necessary supporting documents, Class which Emory shall have a right to review and approve (which approval shall not be unreasonably withheld). Emory may suggest revisions, which Plaintiffs agree to consider in good faith, as long as Emory provides its suggested revisions or comments within seven (7) business days of having received any such document or documents from Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with or other such time as the Settling Parties may agree. Plaintiffs will file the motion for final approval pursuant to the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for Final Approval of this Agreement ordered by the Court. The final approval motion for Final Approval shall seek entry of an order and Final Judgmenta final approval order, including: a. Finally approving a) finding that notice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure; b) finding the Settlement as being a to be fair, reasonable, and adequate settlement for the Class within the meaning of Federal Rules of Civil Procedure 23, Fed. R. Civ. P. 23 and directing the implementation, performance and consummation of the Settlement pursuant to its terms; c) finding that all Class Members shall be bound by the terms Settlement Agreement and conditions all of its terms; d) finding that the Releasors shall be bound by the respective releases set forth in Paragraphs 13 and 14 of this Settlement Agreement, and shall be forever barred from asserting any claims or liabilities against Emory covered by the respective Released Claims against any of the Releasees; b. Dismissing e) approving expressly the provisions in Paragraph 7(e) of the Settlement Agreement allowing payment of Settlement Class Counsel fees and expenses before the Effective Date pursuant to the terms of that paragraph; f) directing that the Action be dismissed with prejudice; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not prejudice as to any obligations created or owed pursuant to this Agreement); e. Permanently barring Emory and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposeswithout costs; and g. Determining g) determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal with prejudice as to the Released Parties shall Emory be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.final;

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementAgreement and certifies the Direct Purchaser Settlement Class, Direct Purchaser Class Plaintiffs, through Plaintiffs’ Interim DPP Lead Counsel, shall, —in accordance with the schedule set forth in the Court’s Preliminary Approval Order, Approval—submit to the Court a separate motion for Final Approval of this Agreement by the Court, the text of which shall be proposed by Interim DPP Lead Counsel, subject to the agreement of the C&S Settling Parties, which agreement shall not be unreasonably withheld. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally finally approving the Settlement as being a fair, reasonable, and adequate settlement for the Direct Purchaser Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation execution of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing dismissing the Action Direct Purchaser Class Action, with prejudiceprejudice as to the C&S Released Parties; c. Dismissing all claims against discharging and releasing the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the C&S Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving ▇. ▇▇▇▇▇▇▇▇▇ continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining e. determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the C&S Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval Approval, preliminarily certifies the Settlement Class, and approves the form and manner of this AgreementSettlement Class Notice, Class then Plaintiffs, through Plaintiffs’ Counsel, Interim Co-Lead Counsel shall, in accordance with the schedule set forth in the Court’s Preliminary Approval OrderApproval, submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim Co-Lead Counsel to Tyson for its review. To the extent that Tyson objects to any aspect of the motion, it shall communicate such objection to Interim Co-Lead Counsel and the Parties shall meet and confer to resolve any such objection in good faith. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in conditions, without material modification of those terms and conditions; b. Determining that the Settlement Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement; b. c. Dismissing the Action with prejudiceprejudice as to Tyson in all complaints asserted by Plaintiffs without further costs or fees; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing Tyson Released Parties of and from all further liability to Plaintiffs and Class Members with respect to Released Claims; e. Enjoining the Releasing Parties from asserting, directly or indirectly, any of the Released Claims (but not as to against any obligations created or owed of the Tyson Released Parties in any forum; f. Confirming that Tyson has provided the appropriate notice pursuant to this Agreementthe Class Action Fairness Act, 28 U.S.C. § 1711 et seq. (“CAFA”); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties Tyson shall be final and appealable and entered forthwith. The Parties shall take use all reasonable steps best efforts to obtain Final Approval of the SettlementSettlement Agreement without modification to any of its material terms and conditions.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval preliminarily approves this Settlement Agreement, Plaintiff shall submit—and Actavis and Merz shall take no position regarding—a motion for final approval by the Court of this Agreement, Settlement Agreement (“Final Approval Motion”) after notice has been disseminated to the Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with pursuant to the schedule set forth in the Court’s Preliminary Approval Order. The Final Approval Motion, submit which Actavis and Merz shall have the reasonable opportunity to review in advance of Plaintiff filing, shall be submitted to the Court a separate motion for Final Approval of this Agreement by within twenty-one days after the Court. The motion for Final Approval -ordered deadline by which members of the Class may object to the Settlement, and shall seek entry of an order and final judgment (“Final JudgmentApproval Order”) substantially in the form attached hereto as Exhibit C: a. Finally approving the finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Plaintiff and the Indirect Purchaser Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23, and directing the implementation, performance and its consummation pursuant to its terms; b. finding that all members of the Class (“Class Members”) shall be bound by this Settlement pursuant Agreement, including the release provisions and covenant not to the terms and conditions sue set forth in this Settlement Agreement; b. Dismissing c. finding that the Action with prejudicenotice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure; c. Dismissing all claims against d. incorporating the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering releases set forth in Paragraphs 11 and 12 of this Settlement Agreement, and forever barring the Class Plaintiffs and Class Members to discharge the Released Parties of and Releasors (as defined in Paragraph 13 below) from all further liability to Plaintiffs and Class Members with respect to the asserting any Released Claims (but not as to defined in Paragraph 11 below) against any obligations created or owed pursuant to this Agreementof the Releasees (as defined in Paragraph 11 below); e. Permanently barring providing for the payment of reasonable attorneys’ fees and enjoining Class Plaintiffs reimbursement of expenses, if any, solely from a settlement fund underwritten by the Settlement Amount and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration amounts received by Plaintiff from other defendants in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on this Action (the Released Claims“Settlement Fund”); f. Reserving continuing providing for payment solely from the Settlement Fund of any incentive award to the named Plaintiff in addition to whatever monies it will receive from the Settlement Fund pursuant to court order; g. directing that the Indirect Purchaser Class Action be dismissed with prejudice as to Actavis and Merz at the appropriate time and, except as provided for herein, without costs or attorneys’ fees recoverable under 15 U.S.C. § 15(a)); h. retaining exclusive jurisdiction over the Settlement for all purposesand the Settlement Agreement, including the administration and consummation of the Settlement; and g. Determining under i. directing that the judgment of dismissal with prejudice of all Indirect Purchaser Class claims against ▇▇▇▇▇▇▇ and Merz shall be final and appealable pursuant to Fed. R. Civ. P. 54(b) that ), there is being no just reason for delay and directing that the judgment of dismissal as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementdelay.

Motion for Final Approval and Entry of Final Judgment. If (A) After Class Notice is issued, and prior to the Court grants Preliminary Approval of this AgreementFairness Hearing, Class Plaintiffs, through Plaintiffs’ Lead Counsel, shallon behalf of the Plaintiff(s), shall move for entry of the Final Approval Order and Final Judgment in accordance this Action: (i) finally certifying solely for settlement purposes the Settlement Class; (ii) finding that the Class Notice constituted the best notice practicable under the circumstances and complied in all respects with the schedule set forth in requirements of Rule 23 of the Court’s Preliminary Approval Order, submit to the Court a separate motion for Final Approval Federal Rules of Civil Procedure and due process; (iii) finally approving this Settlement Agreement by the Court. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement its terms as being a fair, reasonable, reasonable and adequate settlement for of the Class within Settlement Class’ claims against Tower under Rule 23 of the meaning of Federal Rules of Civil Procedure 23Procedure; (iv) directing that, and directing the implementation, performance and consummation of the Settlement pursuant as to the terms Released Parties, the Action be dismissed with prejudice and conditions set forth in this Agreementwithout costs as against the Settling Class Members; b. Dismissing (v) discharging and releasing the Action with prejudiceReleased Claims as to the Released Parties; c. Dismissing all (vi) ▇▇▇▇▇▇▇ and enjoining claims by any Person against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties for contribution, indemnification, or similar claims (however denominated) for all or a portion of any amounts paid or awarded in the Action by way of settlement, judgment, or otherwise; (vii) discharging and releasing the Released Parties from all further liability to Plaintiffs any claims and Class Members with respect causes of action of every nature and description, whether known or unknown, whether arising under federal, state, common or foreign law (including FED. R. CIV. P. 11) that arise out of or relate in any way to the Released Claims institution, prosecution, or settlement of the Action as against Tower, except for claims relating to the enforcement of the Settlement; (but not as to any obligations created or owed viii) determining pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining under FedFED. R. CivCIV. P. 54(b) that there is no just reason for delay and directing that the judgment Final Judgment shall be final and appealable; (ix) reserving the Court’s continuing and exclusive jurisdiction over the Settlement and this Agreement, including the administration and consummation of dismissal this Agreement; and (x) containing such other and further provisions consistent with the terms of this Agreement to which Tower and Class Plaintiffs expressly consent in writing. (B) Prior to the Fairness Hearing, as provided in Section 4, Lead Counsel will timely request by separate motion that the Court approve its Fee and Expense Application. The Fee and Expense Application and the Distribution Plan are matters separate and apart from the Settlement between the Parties. If the Fee and Expense Application or the Distribution Plan is not approved, in whole or in part, it will have no effect on the finality of the Final Approval Order approving the Settlement and the Final Judgment dismissing the Action with prejudice as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the SettlementParties.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval preliminarily approves this Settlement, ▇▇▇▇ shall submit—and Novartis shall not oppose in any court, including on appeal—a motion for final approval by the Court of this Agreement, Settlement (“Final Approval Motion”) after notice has been disseminated to Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with Members pursuant to the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for . The Final Approval of this Agreement by the Court. The motion for Final Approval Motion shall seek entry of an order and final judgment (“Final JudgmentApproval Order”) substantially in the form attached hereto as Exhibit C: a. Finally approving the finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to ▇▇▇▇ and the End-Payor Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23, and directing the implementation, performance and its consummation pursuant to its terms; b. finding that all members of the End-Payor Class (“Class Members”) shall be bound by this Settlement pursuant Agreement, including the release provisions and covenant not to the terms and conditions sue set forth in this Settlement Agreement; b. Dismissing c. finding that the Action with prejudicenotice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure; c. Dismissing d. incorporating the release set forth in Paragraph 11 of this Settlement Agreement, and forever barring the Releasors from asserting any Released Claims against any of the Releasees as defined below; e. ordering that settlement funds may be disbursed as provided in the Final Approval Order or other order of the Court; f. providing for the payment of reasonable attorneys’ fees and reimbursement of costs and expenses solely from the Settlement Fund; g. providing for payment solely from the Settlement Fund of service awards in the amount of $25,000 each to the ▇▇▇▇, in addition to whatever monies each may receive from the Settlement Fund pursuant to a Court-approved plan of allocation; h. directing that all claims against by and on behalf of ▇▇▇▇ and the nonEnd-existing corporate entity “Inmate Telephone Service” Payor Class be dismissed with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not prejudice as to any obligations created Novartis and, except as provided for herein, without costs or owed pursuant to this Agreementattorney’s fees recoverable under 15 U.S.C. § 15(a); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and i. retaining exclusive jurisdiction over the Settlement for all purposesand the Settlement Agreement, including the administration and consummation of the Settlement; and g. Determining under j. directing that the judgment of dismissal with prejudice of all End-Payor Class claims against Novartis shall be final and immediately appealable pursuant to Fed. R. Civ. P. 54(b) that ), there is being no just reason for delay and directing that the judgment of dismissal as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementdelay.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval certifies the End-Payor Classes for purposes of settlement and preliminarily approves the Settlement, End-Payor Plaintiffs shall submit a motion for final approval of this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for Final Approval of this Agreement Settlement by the Court. The motion for Final Approval , after appropriate notice to the End-Payor Classes, and shall seek entry of an order a “Final Judgment and Final JudgmentOrder” substantially in the form preliminarily approved by the Court, with any necessary additional findings of fact and conclusions of law: a. Finally approving the finding this Settlement as being a Agreement and its terms to be fair, reasonable, and adequate settlement for as to End-Payor Plaintiffs and the Class members of the End-Payor Classes within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23Procedure, and directing the implementation, performance and its consummation of the Settlement pursuant to the terms and conditions set forth in this of the Settlement Agreement; b. Dismissing providing for payment of reasonable attorneys’ fees and, in addition to reasonable attorneys’ fees, reimbursement of the costs and expenses from the Settlement Fund (as defined in Paragraph 7); c. providing for payment solely from the Settlement Fund of service awards to the named End-Payor Plaintiffs (in addition to whatever monies they will receive from the Net Settlement Fund pursuant to a Court-approved Allocation Plan); d. directing that upon the Effective Date, the End-Payor Class Action be dismissed as to Pfizer with prejudice; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and reserving exclusive jurisdiction over the Settlement for all purposesand this Settlement Agreement, including the provisions of this Paragraph 5, the administration and consummation of this Settlement, the award of attorneys’ fees and reimbursement of costs and expenses, and the payment of service awards to each of the named End-Payor Plaintiffs, if allowed by the Court; and g. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and f. directing that the judgment of dismissal as to of the Released Parties End-Payor Class Action against Pfizer shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps pursuant to obtain Final Approval Rule 54(b) of the SettlementFederal Rules of Civil Procedure, there being no just reason for delay.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementApproval, Class Plaintiffsthen DPPs, through Plaintiffs’ Counsel, shall, Co-Lead Class Counsel – in accordance with the schedule set forth in the Court’s Preliminary Approval Order, – shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Co-Lead Class Counsel to Hormel Foods for its review. To the extent that Hormel Foods objects to any aspect of the motion, it shall communicate such objection to Co-Lead Class Counsel, and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Certified Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23Procedure, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Determining that the Settlement Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Action with prejudiceprejudice as to Hormel Foods in all class action complaints asserted by DPPs or the Certified Class; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing Hormel Foods Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. f. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties Hormel Foods shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the SettlementSettlement Agreement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand certifies the Settlement Class, Class Plaintiffsthen CIIPPs, through Plaintiffs’ Counsel, shall, Interim Co-Lead Counsel — in accordance with the schedule set forth in the Court’s Preliminary Approval Order, — shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim Co-Lead Counsel to JBS for their review. To the extent that JBS objects to any aspect of the motion, it shall communicate such objection to Interim Co-Lead Counsel and the Parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing Determining that the Action with prejudiceClass Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Actions with prejudice as to JBS in all claims against class action complaints asserted by CIIPPs or the non-existing corporate entity “Inmate Telephone Service” with prejudice.Settlement Class; d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing JBS Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. f. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties JBS shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the SettlementSettlement Agreement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementApproval, Class Plaintiffsthen the Certified Class, through Plaintiffs’ Counsel, shall, Co-Lead Counsel — in accordance with the schedule set forth in the Court’s Preliminary Approval Order, — shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Co-Lead Counsel to ▇▇▇▇▇▇ Farms for its review. To the extent that ▇▇▇▇▇▇ Farms objects to any aspect of the motion, it shall communicate such objection to Co-Lead Counsel and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Certified Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in this Agreementconditions, without material modification of those terms and conditions; b. Dismissing Determining that the Action with prejudiceCertified Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing all claims against complaints asserted by Releasing Parties in the non-existing corporate entity “Inmate Telephone Service” Action with prejudice.prejudice as to ▇▇▇▇▇▇ Farms without further costs or fees; d. Ordering Discharging and releasing the ▇▇▇▇▇▇ Farms Released Parties from all Released Claims; e. Enjoining the Releasing Parties from suing any of the ▇▇▇▇▇▇ Farms Released Parties for any of the Released Claims; f. Filing a declaration prepared by counsel for ▇▇▇▇▇▇ Farms confirming that ▇▇▇▇▇▇ Farms has provided the appropriate notice pursuant to the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims Action Fairness Act, 28 U.S.C. §1711 et seq. (but not as to any obligations created or owed pursuant to this Agreement“CAFA”); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties ▇▇▇▇▇▇ Farms shall be final and appealable and entered forthwith. The Parties shall take use all reasonable steps best efforts to obtain Final Approval of the SettlementSettlement Agreement without modification to any of its material terms and conditions.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand preliminarily certifies the Settlement Class, Class Plaintiffsthen DPPs, through Plaintiffs’ Counsel, shall, Interim Co-Lead Counsel — in accordance with the schedule set forth in the Court’s Preliminary Approval Order, — shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim Co-Lead Counsel to ▇▇▇▇▇▇▇▇ for its review. To the extent that ▇▇▇▇▇▇▇▇ objects to any aspect of the motion, it shall communicate such objection to Interim Co-Lead Counsel and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules Rule of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in this Agreementconditions, without material modification of those terms and conditions; b. Determining that the Settlement Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Action with prejudiceprejudice as to ▇▇▇▇▇▇▇▇ in all class action complaints asserted by DPPs without further costs or fees; c. Dismissing d. Discharging and releasing ▇▇▇▇▇▇▇▇ Released Parties from all claims against Released Claims; e. Enjoining DPPs and members of the non-existing corporate entity “Inmate Telephone Service” with prejudice.Settlement Class from suing any of the ▇▇▇▇▇▇▇▇ Released Parties for any of the Released Claims; d. Ordering f. Confirming that ▇▇▇▇▇▇▇▇ has provided the appropriate notice pursuant to the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims Action Fairness Act, 28 U.S.C. §§ 1711, et seq. (but not as to any obligations created or owed pursuant to this Agreement“CAFA”); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. Federal Rule of Civil Procedure 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties ▇▇▇▇▇▇▇▇ shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps actions as may be necessary to obtain Final Approval of the SettlementSettlement Agreement without modification to any of its material terms and conditions.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval preliminarily approves the Settlement, Plaintiffs shall submit a motion for final approval of this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit to the Court a separate motion for Final Approval of this Agreement Settlement by the Court. The motion for Final Approval , after appropriate notice to the Direct Purchaser Class, and shall seek entry of an order a Final Judgment and Order substantially in the form attached hereto as Exhibit C, with any additional findings of fact and conclusions of law (the “Final Judgment:Judgment and Order”): a. Finally approving the finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Plaintiffs and the members of the Direct Purchaser Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23, and directing the implementation, performance and its consummation of the Settlement pursuant to the terms and conditions set forth in this Agreementits terms; b. Dismissing finding that all members of the Action with prejudiceClass shall be bound by this Settlement Agreement, including the release provisions and covenant not to sue set forth herein; c. Dismissing all claims against finding that notice given constitutes due, adequate, and sufficient notice and meets the non-existing corporate entity “Inmate Telephone Service” with prejudice.requirements of due process and the Federal Rules of Civil Procedure; d. Ordering providing for payment of reasonable attorneys’ fees and reimbursement of the Class Plaintiffs costs and Class Members to discharge expenses from the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims Settlement Fund (but not as to any obligations created or owed pursuant to this Agreementdefined below); e. Permanently barring and enjoining Class providing for payment, solely from the Settlement Fund, of incentive awards to the named Plaintiffs and Class Members in addition to whatever monies they will receive from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause the Settlement Fund pursuant to a Court-approved plan of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claimsallocation; f. Reserving continuing and directing that the Direct Purchaser Class Action be dismissed with prejudice and, except as provided for herein, without costs; g. reserving exclusive jurisdiction over the Settlement for all purposesand this Settlement Agreement, the administration and consummation of this Settlement,the award of attorneys’ fees and reimbursement of costs and expenses, and the payment of incentive awards to each of the named Plaintiffs, if allowed by the Court; h. incorporating the release set forth in Paragraph 13 of this Settlement Agreement, and forever barring the Releasors (as defined in paragraph 13 herein) from asserting any Released Claims (as defined in paragraph 13 herein) against Defendant; and g. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and i. directing that the judgment of dismissal as to the Released Parties of all Direct Purchaser Class claims against Defendant shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementappealable.

Motion for Final Approval and Entry of Final Judgment. If Not less than thirty- five (35) days prior to the date set by the Court grants Preliminary Approval to consider whether this Settlement should be finally approved pursuant to Federal Rule of this AgreementCivil Procedure 23(e)(2), Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with Counsel shall submit a motion for final approval (“Final Approval”) of the schedule set forth in Settlement by the Court’s Preliminary Approval Order, submit to the Court . Class Counsel shall provide Defendant with a separate draft proposed motion for Final Approval of this Agreement the Settlement by the CourtCourt (including any accompanying memorandum of law) in advance of filing and shall consider in good faith any concerns or suggestions expressed by Defendant. Class Counsel shall also provide Defendant with a draft proposed final approval order (“Final Approval Order”) and Judgment, seven days in advance of filing. The motion for Final Approval Settling Parties shall jointly agree on the content of and shall jointly seek entry of an order the Final Approval Order and Final Judgment: a. Finally fully and finally approving the Settlement contemplated by this Agreement and its terms as being a fair, reasonable, and adequate settlement for the Class within the meaning of Federal Rules Rule of Civil Procedure 23, 23 and directing the implementation, performance and its consummation of the Settlement pursuant to the its terms and conditions set forth in this Agreementconditions; b. Dismissing finding that the Action notice given to the Class Members constituted the best notice practicable under the circumstances and complies in all respects with prejudicethe requirements of Federal Rule of Civil Procedure 23 and due process; c. Dismissing all claims against directing that the non-existing corporate entity “Inmate Telephone Service” Action be dismissed with prejudice.prejudice as to Defendant and, except as provided for herein, without costs; d. Ordering discharging and releasing the Class Releasees from all Released Claims; e. permanently barring and enjoining the institution and prosecution, by End- Payor Plaintiffs and Class Members to discharge Members, of any other action against the Released Parties of and from all further liability to Plaintiffs and Class Members with respect Releasees in any forum asserting any claims related in any way to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving reserving continuing and exclusive jurisdiction over the Settlement for Settlement, including all purposes; andfuture proceedings concerning the administration, consummation, and enforcement of this Agreement; g. Determining under Fed. R. Civ. P. determining pursuant to Federal Rule of Civil Procedure 54(b) that there is no just reason for delay and directing entry of a Final Judgment as to Defendant; and h. containing such other and further provisions consistent with the terms of this Agreement to which the Settling Parties expressly consent in writing. Class Counsel also will request that the judgment Court approve the proposed Plan of dismissal Allocation and application for attorneys’ fees and reimbursement of expenses and service awards (as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementdescribed below). C. Releases

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand certifies the Indirect Purchaser Settlement Class, Indirect Purchaser Class Plaintiffs, through Plaintiffs’ Interim IPP Lead Counsel, shall, shall – in accordance with the schedule set forth in the Court’s Preliminary Approval Order, – submit to the Court a separate motion for Final Approval of this Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim IPP Lead Counsel to USALCO for its review, so that USALCO shall have the opportunity to make reasonable comments/revisions before the pleadings are filed with the Court. To the extent that USALCO objects to any aspect of the motion, it shall communicate such objection to Interim IPP Lead Counsel and the parties shall meet and confer to resolve any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally subject to Paragraph 11, finally approving the Settlement as being a fair, reasonable, and adequate settlement for the Indirect Purchaser Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing subject to Paragraph 11, dismissing the Action Class Action, with prejudiceprejudice as to USALCO; c. Dismissing subject to Paragraph 11, discharging and releasing the USALCO Released Parties from all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice.Released Claims; d. Ordering the Class Plaintiffs and Class Members subject to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringingParagraph 11, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving reserving continuing and exclusive jurisdiction over the Settlement for all purposes, including the administration of the Settlement or its execution; and g. Determining e. subject to Paragraph 11, determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties USALCO shall be final and appealable and entered forthwith. The Settling Parties shall take all reasonable steps to obtain Final Approval Judgment of the Settlement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementAgreement and certifies the Direct Purchaser Settlement Class, Direct Purchaser Class Plaintiffs, through Plaintiffs’ Interim DPP Lead Counsel, shall, shall – in accordance with the schedule set forth in the Court’s Preliminary Approval Order, – submit to the Court a separate motion for Final Approval of this Agreement by the Court, the text of which shall be proposed by Interim DPP Lead Counsel, subject to the agreement of the GEO Settling Parties, which agreement shall not be unreasonably withheld. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally finally approving the Settlement as being a fair, reasonable, and adequate settlement for the Direct Purchaser Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation execution of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing dismissing the Action Direct Purchaser Class Action, with prejudiceprejudice as to the GEO Released Parties; c. Dismissing discharging and releasing the GEO Released Parties from all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice.Released Claims; d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving reserving continuing and exclusive jurisdiction over the Settlement for all purposespurposes — including its administration and execution and disputes that may arise concerning the GEO Settling Parties’ cooperation (as set forth in Paragraph 9 of this Agreement); and g. Determining e. determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the GEO Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement. Within ten (10) days of Final Judgment, the Direct Action Direct Purchaser Settlement Class Members and the GEO Settling Parties will file a stipulation of dismissal of the Direct Action Direct Purchaser Settlement Class Members’ claims against the GEO Released Parties, with prejudice.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementAgreement and certifies the Indirect Purchaser Settlement Class, Indirect Purchaser Class Plaintiffs, through Plaintiffs’ Interim IPP Lead Counsel, shall, shall – in accordance with the schedule set forth in the Court’s Preliminary Approval Order, – submit to the Court a separate motion for Final Approval of this Agreement by the Court, the text of which shall be proposed by Interim IPP Lead Counsel, subject to the agreement of the GEO Settling Parties, which agreement shall not be unreasonably withheld. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally finally approving the Settlement as being a fair, reasonable, and adequate settlement for the Indirect Purchaser Settlement Class within the meaning of Federal Rules Rule of Civil Procedure 23, and directing the implementation, performance and consummation execution of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing subject to Paragraph 10, dismissing the Action Indirect Purchaser Class Action, with prejudiceprejudice as to the GEO Released Parties; c. Dismissing all claims against subject to Paragraph 10, discharging and releasing the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the GEO Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving ▇. ▇▇▇▇▇▇▇▇▇ continuing and exclusive jurisdiction over the Settlement for all purposespurposes — including its administration and execution and disputes that may arise concerning the GEO Settling Parties’ cooperation (as set forth in Paragraph 9 of this Agreement); and g. Determining e. determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the GEO Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the SettlementSettlement and Final Judgment. Within ten (10) days after the occurrence of Final Judgment, the Direct Action Indirect Purchaser Settlement Class Members and the GEO Settling Parties will file a stipulation of dismissal of the Direct Action Indirect Purchaser Settlement Class Members’ claims against the GEO Released Parties, with prejudice.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this Agreementand certifies the Settlement Class, Class Plaintiffsthen EUCPs, through Plaintiffs’ Counsel, shall, Lead Counsel — in accordance with the schedule set forth in the Court’s Preliminary Approval Order, shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Lead Counsel to O.K. Foods for its review. To the extent that O.K. Foods objects to any aspect of the motion, it shall communicate such objection to Lead Counsel and the parties shall meet and confer about any such objection. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Determining that the Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Action with prejudiceprejudice as to O.K. Foods in all class action complaints asserted by EUCPs; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing O.K. Foods Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring Enjoining EUCPs and enjoining members of the Settlement Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, suing any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the O.K. Foods Released Claims or receiving Parties for any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims; f. Confirming that O.K. Foods has provided the appropriate notice pursuant to the Class Action Fairness Act, 28 U.S.C. 5171 1, et seq. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties O.K. Foods shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the SettlementSettlement Agreement.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementAgreement and certifies the Direct Purchaser Settlement Class, Direct Purchaser Class Plaintiffs, through Plaintiffs’ Interim DPP Lead Counsel, shall, —in accordance with the schedule set forth in the Court’s Preliminary Approval Order, Approval—submit to the Court a separate motion for Final Approval of this Agreement by the Court, the text of which shall be proposed by Interim DPP Lead Counsel, subject to the agreement of the Kemira Settling Parties, which agreement shall not be unreasonably withheld. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally finally approving the Settlement as being a fair, reasonable, and adequate settlement for the Direct Purchaser Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation execution of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing dismissing the Action Direct Purchaser Class Action, with prejudiceprejudice as to the Kemira Released Parties; c. Dismissing discharging and releasing the Kemira Released Parties from all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice.Released Claims; d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining e. determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Kemira Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement. Within ten (10) days of Final Judgment, the Direct Purchaser Settlement Class Members and Kemira will file a stipulation of dismissal of the Direct Purchaser Settlement Class Members’ claims against the Kemira Released Parties, with prejudice.

Motion for Final Approval and Entry of Final Judgment. If Prior to the date set by the Court grants Preliminary Approval of to consider whether this AgreementSettlement should be finally approved, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, Counsel shall submit to the Court a separate motion for Final Approval final approval of this Agreement the Settlement by the Court. The motion for Final Approval Settling Parties shall jointly seek entry of an order the Final Approval Order and Final Judgment: a. Finally (a) certifying the Settlement Class, as defined in this Settlement Agreement, pursuant to Federal Rule of Civil Procedure 23, solely for purposes of this Settlement; (b) fully and finally approving the Settlement contemplated by this Settlement Agreement and its terms as being a fair, reasonable, reasonable and adequate settlement for the Class within the meaning of Federal Rules Rule of Civil Procedure 23, 23 and directing the implementation, performance and its consummation of the Settlement pursuant to the its terms and conditions set forth conditions. (c) finding that the notice given to the Class Members constituted the best notice practicable under the circumstances and complies in this Agreementall respects with the requirements of Federal Rule of Civil Procedure 23 and due process; b. Dismissing (d) directing that the Action be dismissed with prejudiceprejudice as to Taitsu and, except as provided for herein, without costs; c. Dismissing (e) discharging and releasing the Releasees from all claims against Released Claims; (f) permanently barring and enjoining the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class institution and prosecution, by Indirect Purchaser Plaintiffs and Class Members to discharge Members, of any other action against the Released Parties of and from all further liability to Plaintiffs and Class Members with respect Releasees in any court asserting any claims related in any way to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving g) reserving continuing and exclusive jurisdiction over the Settlement, including all future proceedings concerning the administration, consummation and enforcement of this Settlement for all purposes; andAgreement; g. Determining under Fed. R. Civ. P. (h) determining pursuant to Federal Rule of Civil Procedure 54(b) that there is no just reason for delay and directing that the entry of a final judgment of dismissal as to Taitsu; and (i) containing such other and further provisions consistent with the Released Parties shall be final and appealable and entered forthwithterms of this Settlement Agreement to which the parties expressly consent in writing. The Parties shall take all reasonable steps to obtain Final Approval of the Settlement.LAW OFFICES COTCHETT, ▇▇▇▇▇ &

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval preliminarily approves the Settlement, and after notice has been provided to the Settlement Class, Plaintiffs shall submit a motion for final approval of this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit to Settlement by the Court a separate motion for Final Approval of this Agreement by the Court. The motion for Final Approval and shall seek entry of an order a Final Order and Judgment with any additional findings of fact and conclusions of law (the “Final Order and Judgment:”): a. Finally approving the (a) finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Plaintiffs and the members of the Settlement Class within the meaning of Federal Rules Rule of Civil Procedure 23, 23 and directing its consummation pursuant to its terms; (b) reserving the implementation, performance and consummation Settlement Fund (as defined below) for the payment of the costs and expenses of this litigation; (c) in the event the Court does not approve Plaintiffs’ request to reserve the Settlement Fund for the payment of the costs and expenses of this litigation, Plaintiffs will apply to distribute the net Settlement Fund to the proposed Classes, including payment of and reimbursement for litigation costs and expenses from the Settlement Fund (as defined below) and providing for payment solely from the Settlement Fund of service awards to the Class Representative Plaintiffs in addition to whatever monies they will receive from the Settlement Fund pursuant to the terms and conditions set forth in this Agreementa Court-approved Plan of Allocation; b. Dismissing (d) directing that the Plaintiffs’ Action be dismissed with prejudiceprejudice as to Settling Defendants and, except as provided for herein, without attorney’s fees recoverable under 15 U.S.C. § 15(a) or similar state statutes or costs; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and e) reserving exclusive jurisdiction over the Settlement for all purposesand this Settlement Agreement, including the provisions of this paragraph, the administration and consummation of this Settlement, the award of attorneys’ fees and reimbursement of costs and expenses, and the payment of service awards to each of the Class Representative Plaintiffs, if allowed by the Court; and g. Determining under (f) directing that the judgment of dismissal of all Class claims against Settling Defendants shall be final and appealable pursuant to Fed. R. Civ. P. 54(b) that ), there is being no just reason for delay and directing that the judgment of dismissal as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementdelay.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of this AgreementApproval, Class Plaintiffsthen EUCPs, through Plaintiffs’ Counsel, shall, Lead Counsel in accordance with the schedule set forth in the Court’s Preliminary Approval OrderApproval, shall submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. As soon as practicable in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Lead Counsel to ▇▇▇▇▇▇ Farms for its review. To the extent that ▇▇▇▇▇▇ Farms objects to any aspect of the motion, it shall communicate such objection to Lead Counsel and the parties shall meet and confer about any such objection and attempt to resolve that issue in good faith. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Certified Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Determining that the Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement and the Fairness Hearing, and constituted due and sufficient notice for all other purposes to all Persons entitled to receive notice; c. Dismissing the Action with prejudiceprejudice as to ▇▇▇▇▇▇ Farms in all class action complaints asserted by EUCPs; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the Released Parties of and releasing ▇▇▇▇▇▇ Farms from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring Enjoining EUCPs and enjoining members of the Certified Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, suing ▇▇▇▇▇▇ Farms for any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims; f. Confirming that ▇▇▇▇▇▇ Farms has provided the appropriate notice pursuant to the Class Action Fairness Act, 28 U.S.C. 1715, et seq. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties ▇▇▇▇▇▇ Farms shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the SettlementSettlement Agreement.

Motion for Final Approval and Entry of Final Judgment. If Not less than thirty- five (35) days prior to the date set by the Court grants Preliminary Approval to consider whether this Settlement should be finally approved pursuant to Federal Rule of this AgreementCivil Procedure 23(e)(2), Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with Counsel shall submit a motion for final approval (“Final Approval”) of the schedule set forth in Settlement by the Court’s Preliminary Approval Order, submit to the Court . Class Counsel shall provide Defendant with a separate draft proposed motion for Final Approval of this Agreement by the Court. The motion for Final Approval shall seek entry of an order and Final Judgment:the a. Finally fully and finally approving the Settlement contemplated by this Agreement and its terms as being a fair, reasonable, reasonable and adequate settlement for the Class within the meaning of Federal Rules Rule of Civil Procedure 23, 23 and directing the implementation, performance and its consummation of the Settlement pursuant to the its terms and conditions set forth in this Agreementconditions; b. Dismissing finding that the Action notice given to the Class Members constituted the best notice practicable under the circumstances and complies in all respects with prejudicethe requirements of Federal Rule of Civil Procedure 23 and due process; c. Dismissing all claims against directing that the non-existing corporate entity “Inmate Telephone Service” Action be dismissed with prejudice.prejudice as to Defendant and, except as provided for herein, without costs; d. Ordering discharging and releasing the Class Releasees from all Released Claims; e. permanently barring and enjoining the institution and prosecution, by Plaintiffs and Class Members to discharge Members, of any other action against the Released Parties of and from all further liability to Plaintiffs and Class Members with respect Releasees in any court asserting any claims related in any way to the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)Claims; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving ▇. ▇▇▇▇▇▇▇▇▇ continuing and exclusive jurisdiction over the Settlement for Settlement, including all purposes; andfuture proceedings concerning the administration, consummation and enforcement of this Agreement; g. Determining under Fed. R. Civ. P. determining pursuant to Federal Rule of Civil Procedure 54(b) that there is no just reason for delay and directing entry of a final judgment as to Defendant; and h. containing such other and further provisions consistent with the terms of this Agreement to which the parties expressly consent in writing. Class Counsel also will request that the judgment Court approve the proposed Distribution Plan and application for attorneys’ fees and reimbursement of dismissal expenses and service awards (as to the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementdescribed below). C. Releases

Motion for Final Approval and Entry of Final Judgment. If 1. On or before the deadline set by the Court grants Preliminary Approval of this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit to Class Counsel shall file a motion for final approval of the Court a separate motion Settlement (the “Motion for Final Approval”). In the Motion for Final Approval of this Agreement by and at the Fairness Hearing, the Settling Parties will request that the Court: (a) enter the Final Approval Order in the form attached as Exhibit G to this Agreement, provided that any modifications to the Final Approval Order must be acceptable to all Class Representatives and the Allergan Defendants; (b) finally certify the Class; (c) approve and adopt the Agreement as final, fair, reasonable, adequate, and binding on all Class Members; (d) enter judgment dismissing the Action with prejudice and directing the dismissal with prejudice of any of the Other Actions; and (e) permanently enjoin any Class Member from asserting or pursuing any Released Claim against any Released Entity in any forum. The motion for Final Approval shall seek entry of an order Order and Final JudgmentJudgment shall contain provisions: a. Finally certifying the Class for settlement purposes; fully and finally approving the Settlement contemplated by this Agreement and its terms as being a fair, reasonable, and adequate settlement for the Class within the meaning of Federal Rules Rule of Civil Procedure 2323 and directing its consummation pursuant to its terms and conditions; finding that the Notice given to the Class Members constituted the best notice practicable under the circumstances and complies in all respects with the requirements of Federal Rule of Civil Procedure 23 and due process; b. entering judgment dismissing the Action with prejudice as to the Allergan Defendants and, except as provided for herein, without costs; c. directing that the Other Actions be dismissed with prejudice as to the Allergan Defendants and, except as provided for herein, without costs; d. discharging and releasing the Released Entities from all Released Claims; e. permanently barring and enjoining the institution and prosecution by Class Members of any other action against the Released Entities in any forum asserting any claims related in any way to the Released Claims; f. reserving and continuing exclusive jurisdiction over the Settlement, including the Escrow Account, the Escrow Agent as its administrator, and directing all future proceedings concerning the implementationadministration, performance consummation, and consummation enforcement of the Settlement pursuant to the terms and conditions set forth in this Agreement; b. Dismissing the Action with prejudice; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to the Released Claims (but not as to any obligations created or owed g. determining pursuant to this Agreement); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause Federal Rule of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and exclusive jurisdiction over the Settlement for all purposes; and g. Determining under Fed. R. Civ. P. Civil Procedure 54(b) that there is no just reason for delay and directing entry of a Final Approval Order as to Plaintiffs and the Allergan Defendants; and h. containing such other and further provisions consistent with the terms of this Agreement to which the Settling Parties expressly consent in writing. Class Counsel also will request that the judgment Court approve the proposed Plan of dismissal Allocation and application for attorneys’ fees and reimbursement of expenses, as to described below. 2. Class Counsel shall provide the Released Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval Allergan Defendants with a draft of the SettlementMotion for Final Approval, together with any accompanying memorandum of law at least five (5) business days in advance of filing and shall consider in good faith any comments the Allergan Defendants may have. Class Counsel shall not file such a motion without the Allergan Defendants’ consent, which consent shall not be unreasonably withheld.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval of preliminarily approves this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with Settlement (the schedule set forth in the Court’s “Preliminary Approval Order”), submit Settling Plaintiffs and the Settlement Class shall submit, and Settling Defendant shall assent to and assist as necessary, a motion for final approval of this Settlement by the Court (the “Final Approval Motion”), after Notice has been disseminated to the Court a separate motion for Settlement Class pursuant to the Preliminary Approval Order. The Final Approval of this Agreement by the Court. The motion for Final Approval Motion shall seek entry of an order and final judgment (“Final JudgmentApproval Order”), which Settling Defendant shall have the opportunity to review and approve before it is submitted to the Court: a. Finally approving the Finding this Settlement as being Agreement and its terms to be a fair, reasonable, and adequate settlement for as to Settling Plaintiffs and the Settlement Class within the meaning of Fed. R. Civ. P. 23 and directing its consummation pursuant to its terms; b. Finding that Notice given constitutes due, adequate, and sufficient notice and meets the requirements of due process and the Federal Rules of Civil Procedure 23, and directing the implementation, performance and consummation Procedure; c. Finding that all members of the Settlement pursuant Class who have not executed timely and valid or otherwise Court-approved requests for exclusion shall be bound by this Settlement Agreement, including the release provisions and covenant not to the terms and conditions sue set forth in this Settlement Agreement; b. Dismissing d. Incorporating the Action with prejudice; c. Dismissing all claims against releases set forth in Paragraphs 12 and 13, below, and forever barring the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs and Class Members to discharge the Released Parties of and Releasors (as defined in Paragraph 12) from all further liability to Plaintiffs and Class Members with respect to the asserting any Released Claims (but not as to defined in Paragraph 12) against any obligations created or owed pursuant to this Agreement)of the Releasees as defined below; e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. Reserving continuing and Retaining exclusive jurisdiction over the Settlement and this Settlement Agreement, including the administration and consummation of this Settlement; f. Directing that all claims by and on behalf of the Settling Plaintiffs and the Settlement Class be dismissed with prejudice as to Releasees only and, except as provided for all purposesherein, with prejudice and without costs or attorney’s fees recoverable under 15 U.S.C. § 15(a); and g. Determining under pursuant to Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal Final Approval Order in the Action as to the Released Parties Releasees shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementimmediately appealable.

Motion for Final Approval and Entry of Final Judgment. If the Court grants Preliminary Approval Approval, preliminarily certifies the Settlement Class, and approves the form and manner of this AgreementSettlement Class Notice, Class then Plaintiffs, through Plaintiffs’ Counsel, Interim Co-Lead Class Counsel shall, in accordance with the schedule set forth in the Court’s Preliminary Approval OrderApproval, submit to the Court a separate motion for Final Approval of this Settlement Agreement by the Court. A reasonable time in advance of submission to the Court, the papers in support of the motion for Final Approval shall be provided by Interim Co-Lead Counsel to ▇▇▇▇ for its review. To the extent that ▇▇▇▇ objects to any aspect of the motion, it shall communicate such objection to Interim Co-Lead Class Counsel and the Parties shall meet and confer to resolve any such objection in good faith. The motion for Final Approval shall seek entry of an order and Final Judgment: a. Finally approving the Settlement Agreement as being a fair, reasonable, and adequate settlement for the Settlement Class within the meaning of Federal Rules of Civil Procedure 23, and directing the implementation, performance performance, and consummation of the Settlement pursuant to the Agreement and its material terms and conditions set forth in conditions, without material modification of those terms and conditions; b. Determining that the Settlement Class Notice constituted the best notice practicable under the circumstances of this Settlement Agreement; b. c. Dismissing the Action with prejudiceprejudice as to ▇▇▇▇ in all complaints asserted by Plaintiffs without further costs or fees; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs Discharging and Class Members to discharge the releasing ▇▇▇▇ Released Parties of and from all further liability to Plaintiffs and Class Members with respect to Released Claims; e. Enjoining the Releasing Parties from asserting, directly or indirectly, any of the Released Claims (but not as to against any obligations created or owed of the ▇▇▇▇ Released Parties in any forum; f. Confirming that ▇▇▇▇ has provided the appropriate notice pursuant to this Agreementthe Class Action Fairness Act, 28 U.S.C. § 1711 et seq. (“CAFA”); e. Permanently barring and enjoining Class Plaintiffs and Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity that asserts the Released Claims or receiving any settlement consideration in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause of action in law or equity based on the Released Claims f. g. Reserving continuing and exclusive jurisdiction over the Settlement Agreement for all purposes; and g. h. Determining under Fed. R. Civ. P. 54(b) that there is no just reason for delay and directing that the judgment of dismissal as to the Released Parties ▇▇▇▇ shall be final and appealable and entered forthwith. The Parties shall take use all reasonable steps best efforts to obtain Final Approval of the SettlementSettlement Agreement without modification to any of its material terms and conditions.

Motion for Final Approval and Entry of Final Judgment. If Thirty (30) days prior to the date of the Settlement Hearing set by the Court grants Preliminary Approval of this Agreement, Class Plaintiffs, through Plaintiffs’ Counsel, shall, in accordance with the schedule set forth in the Court’s Preliminary Approval Order, submit to the extent permitted by the Court, Exchange-Based Plaintiffs’ Counsel shall make a motion to the Court a separate motion for Final Approval the final approval of this Agreement by the Court. The motion for Final Approval Settlement, and the Settling Parties shall jointly seek entry of an order the Final Approval Order and Final JudgmentJudgment on substantially the following terms: a. Finally 7.1. Fully and finally approving the Settlement contemplated by this Agreement as being a fair, reasonable, and adequate settlement for the Class within the meaning of Rule 23 of the Federal Rules of Civil Procedure 23, and directing its consummation pursuant to its terms and conditions; 7.2. Finding that the implementation, performance Notice constituted the best notice practicable under the circumstances and consummation complied in all respects with the requirements of Rule 23 of the Settlement pursuant to the terms Federal Rules of Civil Procedure and conditions set forth in this Agreementdue process; b. Dismissing 7.3. Directing that the Action be dismissed with prejudiceprejudice as to Barclays and, except as provided for herein, without costs; c. Dismissing all claims against the non-existing corporate entity “Inmate Telephone Service” with prejudice. d. Ordering the Class Plaintiffs 7.4. Discharging and Class Members to discharge the Released Parties of and from all further liability to Plaintiffs and Class Members with respect to releasing the Released Claims (but not as to any obligations created or owed pursuant to this Agreement)the Releasees; e. 7.5. Permanently barring and enjoining Class the institution and prosecution by Exchange-Based Plaintiffs and any Class Members from bringing, filing, commencing, prosecuting (or further prosecuting), or intervening in, Member of any other lawsuit, arbitration, or administrative, regulatory arbitration or other proceeding or cause of action in law or equity that asserts against the Released Claims or receiving any settlement consideration Releasees in any other lawsuit, arbitration, or administrative, regulatory or other proceeding or cause jurisdiction asserting any of action in law or equity based on the Released Claims; f. 7.6. Reserving the Court’s continuing and exclusive jurisdiction over the Settlement for Settlement, including all purposes; andfuture proceedings concerning the administration and enforcement of this Agreement; g. 7.7. Determining under Fed. R. Civ. P. pursuant to Rule 54(b) of the Federal Rules of Civil Procedure that there is no just reason for delay and directing that the judgment entry of dismissal a final Judgment as to Barclays; and 7.8. Containing such other and further provisions consistent with the Released terms of this Agreement to which the Settling Parties shall be final and appealable and entered forthwith. The Parties shall take all reasonable steps to obtain Final Approval of the Settlementexpressly consent in writing.