Common use of MOTION FOR FINAL APPROVAL Clause in Contracts

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employees. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for the c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employees. Class Counsel’s motion for Final Approval of the Settlement, including Final Approval of the (1) Attorney Fee Award, (2) Cost Award, (3) Administrative Costs, (4) Class Representative Enhancement, and (5) PAGA Payment, shall be filed at least sixteen (16) Court days before the Final Approval Hearing. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Settlement Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. A material modification would include, but not necessarily be limited to, any alteration of the Gross Settlement Amount. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.and

MOTION FOR FINAL APPROVAL. a. Upon expiration of the Response Deadline, Class Counsel will file unopposed motions and memoranda memorandums in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative the Administration Costs; (4) the Class Representative EnhancementEnhancement Payment; and (5) the PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the ), pursuant to which all Participating Class Members and the PAGA shall release all Released Claims of the Eligible Aggrieved EmployeesClaims. b. If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant Defendants to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement Payment, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. Although Plaintiff shall retain the right to appeal those awards. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, ; and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. i. Unless otherwise ordered by the Court, Class Counsel will file unopposed motions with the Court their motion for the Class Counsel Fees Payment, Class Counsel Litigation Expenses Payment, and memoranda in support thereof Class Representative Service Payments no later than the date Plaintiffs file the Motion for Final Approval, and the application will be scheduled to be heard by the Court at the Final Approval Hearing. Plaintiffs shall provide a draft of the Motion for Final Approval to Defendant for their review at least ten (10) calendar days before the filing deadline. Defendant must provide their comments concerning the Motion for Final Approval within seven (7) calendar days of receipt. ii. If any opposition is filed to the Motion for Final Approval, then no later than five (5) court days before the Final Approval Hearing, both Parties may file a reply in support of the Motion for Final Approval. iii. If the Court does not grant final approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring or grants final approval conditioned on any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employees. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under material change to the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, then the Parties agree they shall be equally responsible work together in good faith to address any concerns raised by the Court and propose a revised Settlement for the Settlement Administrator's Administration Costs through that dateCourt’s approval. An However, an award by the Court of a lesser amount than that sought by Plaintiff Plaintiffs and Class Counsel for thethe PAGA Payment, Class Representative Service Payments, Class Counsel Fees Payment, or Class Counsel Litigation Expenses Payment will not constitute a material modification to the Settlement. c. iv. Upon final approval of the Settlement by the Court at or after the Final Approval of the SettlementHearing, the Parties shall will present to for the Court a proposed Final Approval Order, approving Court’s approval and entry the Settlement and entering Judgment in accordance therewithJudgment. After entry of the Judgment, the Court shall will have continuing jurisdiction over the Class Action and the Settlement solely for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, ; and (3) addressing such post-Judgment matters as may be appropriate under Court court rules and or applicable law.

MOTION FOR FINAL APPROVAL. a. Upon expiration of the Objection/Exclusion Deadlines, Class Counsel will file unopposed motions and memoranda memorandums in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: : (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative the Administration Costs; (4) the Class Representative EnhancementEnhancement Payment; and (5) the PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims who do not opt out of the Eligible Aggrieved EmployeesSettlement. b. If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount Total Consideration or any amounts that otherwise would have been owed under this Agreement. Further, should this occurexcept that Defendant shall pay fifty percent (50%) of the Administration Costs, and Plaintiff shall pay the Parties agree they shall be equally responsible for remaining fifty percent (50%) of the Settlement Administrator's Administration Costs through that dateCosts. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement Payment, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Upon expiration of the Objection/Exclusion Deadlines, Class Counsel will file unopposed motions and memoranda memorandums in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative the Administration Costs; (4) the Class Representative EnhancementEnhancement Payments; and (5) the PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims who do not opt out of the Eligible Aggrieved EmployeesSettlement. Counsel for Defendant shall be provided sufficient opportunity to review the Motion for Final Approval before filing with the Court. b. If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they Plaintiffs shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff Plaintiffs and Class Counsel for thethe Class Representative Enhancement Payments, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. (i) Class Counsel will file unopposed motions and memoranda memorandums in support thereof for of Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Attorneys’ Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative EnhancementEnhancement Payment; and (5) the PAGA Payment. The final approval/settlement fairness hearing will be held no sooner than thirty (30) calendar days after the Response Deadline. Class Counsel will be responsible for drafting all documents necessary to obtain final approval. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved EmployeesClass Members who do not opt out of the Settlement. b. (ii) If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs incurred through that date, which shall not be more than $17,500. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement, Attorneys’ Fee Award, Cost Award or Settlement Administrator Administration Costs Award will not constitute a material modification to the Settlement within the meaning of this paragraph. c. (iii) Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving of the Settlement and entering Judgment in accordance therewith. After entry of Judgment, pursuant to CRC 3.769(h), the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) interpreting and enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules rules, this Settlement Agreement, and applicable law.

MOTION FOR FINAL APPROVAL. a. (i) Class Counsel will file unopposed motions and memoranda in support thereof for of Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Paymentas described herein. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims who do not opt out of the Eligible Aggrieved EmployeesSettlement. b. (ii) If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for one-third of the Settlement Administrator's ’s Administration Costs incurred through that date. An award by the Court of a lesser amount than sought by Plaintiff Plaintiffs and Class Counsel for thethe Class Representative Enhancement, Attorneys’ Fee Award, or Cost Award will not constitute a material modification to the Settlement within the meaning of this paragraph. Notwithstanding the foregoing, the Parties and Class Counsel will cooperate with each other and use diligent and reasonable efforts to cure any deficiencies noted by the Court in attempting to secure Final Approval of the Settlement. c. (iii) Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving of the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action Litigation for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-post- Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; and (4) the Class Representative Enhancement; and (5) PAGA PaymentEnhancement Payments. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved EmployeesMembers. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff Plaintiffs and Class Counsel for thethe Class Representative Enhancement Payments, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employees. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After Such entry of Judgmentfinal Judgment shall operate to permanently bar and enjoin all Class Members (excluding those who submit a valid and timely Opt-Out form) from instituting, commencing, prosecuting, or pursuing, either directly or in any other capacity, any of the claims, damages, causes of action, or claims for attorneys’ fees asserted in the Action or identified as Released Claims in this Agreement. Notwithstanding the entry of final judgment in the Actions, the Court shall have continuing retain jurisdiction over the Class Action for purposes of: to interpret and enforce this Stipulation of Settlement pursuant to California Code of Civil (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-post- Judgment matters as may be appropriate under Court rules and applicable law. d. Except as to Class Members who timely submit a valid Exclusion Form the Preliminary Approval Order and Final Judgment will contain provisions enjoining Plaintiff and the Class Members from prosecuting the claims released herein and enjoining Plaintiff and the Class Members from initiating or continuing other proceedings regarding the claims released herein, including but not limited to filing any claims for monetary relief of the Released Claims before the Division of Labor Standards and Enforcement ("DLSE") or in any forum whatsoever. Inclusion of these provisions in the Order of Preliminary Approval Order and Final Judgment and Order of Final Approval is a material part of the consideration for this Settlement. After approval of the Stipulation of Settlement at the Final Approval Hearing and upon receipt of the final payment, the Class Participants and the Class Representative each release the Released Parties, and each of them, of and from any and all of the Released Claims.

MOTION FOR FINAL APPROVAL. a. Unless otherwise ordered by the Court, Class Counsel will file unopposed motions with the Court their motion for the Class Counsel Fees Payment, Class Counsel Litigation Expenses Payment, and memoranda in support thereof Class Representative Service Payments no later than the date Plaintiffs files the Motion for Final Approval, and the application will be scheduled to be heard by the Court at the Final Approval Hearing. b. No later than sixteen (16) court days before the Final Approval Hearing, the Plaintiffs will file with the Court a motion for final approval of the Settlement, PAGA Payment, and payment of the Settlement Administration Expenses. c. If any opposition is filed to the motion for final approval and/or the motion for the Class Counsel Fees Payment, Class Counsel Litigation Expenses Payment, Class Representative Service Payments, and PAGA Payment, then no later than five (5) court days before the following payments Final Approval Hearing, both Parties may file a reply in accord with the terms support of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) motion for final approval, and Plaintiffs and Class Counsel may also file a reply in support of their motion for the Class Representative Enhancement; and (5) PAGA Payment. Service Payments, Class Counsel will also move the Court for an order of Final Approval (Fees Payment, and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved EmployeesCounsel Litigation Expenses Payment. b. d. If the Court denies Final Approval does not grant final approval of the Settlement with prejudice, or if the Court's Final Approval of the Settlement is reversed or materially modified grants final approval conditioned on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under any material change to the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, then the Parties agree they shall be equally responsible work together in good faith to address any concerns raised by the Court and propose a revised Settlement for the Settlement Administrator's Administration Costs through that dateCourt’s approval. An However, an award by the Court of a lesser amount than that sought by Plaintiff Plaintiffs and Class Counsel for thethe PAGA Payment, Class Representative Service Payments, Class Counsel Fees Payment, or Class Counsel Litigation Expenses Payment will not constitute a material modification to the Settlement within the meaning of this Section. c. e. Upon final approval of the Settlement by the Court at or after the Final Approval of the SettlementHearing, the Parties shall will present to for the Court a proposed Final Approval Order, approving Court’s approval and entry the Settlement and entering Judgment in accordance therewithJudgment. After entry of the Judgment, the Court shall will have continuing jurisdiction over the Class Action and the Settlement solely for purposes of: of (1i) enforcing this Settlement Agreement; , (2ii) addressing settlement administration matters, and (3iii) addressing such post-Judgment matters as may be appropriate under Court court rules and or applicable law.

MOTION FOR FINAL APPROVAL. a. Upon expiration of the Objection/Exclusion Deadlines, Class Counsel will file unopposed motions and memoranda memorandums in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative the Administration Costs; (4) the Class Representative EnhancementEnhancement Payments; and (5) the PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employees.also b. If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they Plaintiffs shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff Plaintiffs and Class Counsel for thethe Class Representative Enhancement Payments, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Upon expiration of the Response Deadline, Class Counsel will file unopposed motions and memoranda memorandums in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative the Administration Costs; (4) the Class Representative EnhancementEnhancement Payment; and (5) the PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the ), pursuant to which all Participating Class Members and the PAGA shall release all Released Claims of the Eligible Aggrieved EmployeesClaims. b. If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement Payment, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, ; and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Within sixteen (16) court days before the Final Approval Hearing, Class Counsel will file unopposed motions a motion and memoranda memorandum in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1i) the Attorney Fee Award; (2ii) the Cost Award; (3iii) Administrative Administration Costs; (4iv) the Class Representative EnhancementEnhancement Payment; and (5v) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the ), pursuant to which all Participating Class Members and the PAGA shall release all Released Claims of the Eligible Aggrieved EmployeesClaims. b. If The Settlement Administrator shall submit a declaration in support R I s M3 otiOon Dfor LFinaQl AWpproLval Iof Ithi¶s Settlement detailing the number of Notice Packets mailed and remailed to Class Members, number of undeliverable Notice Packets, number of valid and timely Exclusion Forms received, number of valid and timely written objections received, average, highest, and lowest amount of the Individual Settlement Shares, Administration Costs, and any other information as the Parties mutually agree or the Court denies Final Approval of orders the Settlement with prejudice, or if the Court's Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant Administrator to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for theprovide. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1i) enforcing this Settlement Agreement; (2ii) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.and

MOTION FOR FINAL APPROVAL. a. Unless otherwise ordered by the Court, Class Counsel will file unopposed motions with the Court their motion for the Class Counsel Fees Payment, Class Counsel Litigation Expenses Payment, and memoranda in support thereof Class Representative Service Payment no later than the date Plaintiff files the Motion for Final Approval, and the application will be scheduled to be heard by the Court at the Final Approval Hearing. b. No later than sixteen (16) court days before the Final Approval Hearing, the Plaintiff will file with the Court a motion for final approval of the Settlement, PAGA Payment, and payment of the Settlement Administration Expenses. c. If any opposition is filed to the motion for final approval and/or the motion for the Class Counsel Fees Payment, Class Counsel Litigation Expenses Payment, Class Representative Service Payment, and PAGA Payment, then no later than five (5) court days before the following payments Final Approval Hearing, both Parties may file a reply in accord with the terms support of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) motion for final approval, and Plaintiff and Class Counsel may also file a reply in support of their motion for the Class Representative Enhancement; and (5) PAGA Service Payment. , Class Counsel will also move the Court for an order of Final Approval (Fees Payment, and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved EmployeesCounsel Litigation Expenses Payment. b. d. If the Court denies Final Approval does not grant final approval of the Settlement with prejudiceor grants final approval conditioned on any material change to the Settlement (i.e., or if the scope of release to be granted by Participating Class Members), then the Parties shall work together in good faith to address any concerns raised by the Court and propose a revised Settlement for the Court's Final Approval of the Settlement is reversed or materially modified on appellate review’s approval. However, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's Administration Costs through that date. An an award by the Court of a lesser amount than that sought by Plaintiff and Class Counsel for thethe PAGA Payment, Class Representative Service Payment, Class Counsel Fees Payment, or Class Counsel Litigation Expenses Payment will not constitute a material modification to the Settlement within the meaning of this Section. c. e. Upon final approval of the Settlement by the Court at or after the Final Approval of the SettlementHearing, the Parties shall will present to for the Court a proposed Final Approval Order, approving Court’s approval and entry the Settlement and entering Judgment in accordance therewithJudgment. After entry of the Judgment, the Court shall will have continuing jurisdiction over the Class Action and the Settlement solely for purposes of: of (1i) enforcing this Settlement Agreement; , (2ii) addressing settlement administration matters, and (3iii) addressing such post-Judgment matters as may be appropriate under Court court rules and or applicable law.

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employees.of b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant Defendants to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law. The Final Approval Order and Judgment will be posted on the Settlement Administrator’s website.

MOTION FOR FINAL APPROVAL. a. Upon expiration of the Objection/Exclusion Deadlines, Class Counsel will file unopposed motions and memoranda memorandums in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims who do not opt out of the Eligible Aggrieved EmployeesSettlement. Class counsel will submit to Defendants counsel drafts of the motion for Final Approval of settlement to class members. Defendants’ counsel will not unreasonably withhold approval. Plaintiff’s counsel will not submit motions to the Court without Defendants’ counsel’s approval. b. If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for theor c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employees.the b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Maximum Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement Payment, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law. d. The Settlement Administrator will create a website to notify Class Members of any change to the date or location of the Final Approval Hearing and to give Class Members notice of Final Judgement.

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employees. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant Defendants to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for the c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; and (4) the Class Representative Enhancement; and (5) PAGA Payment. Class Counsel will also move the Court for an and order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved EmployeesMembers. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Upon expiration of the Objection/Exclusion Deadlines, Class Counsel will file unopposed motions and memoranda memorandums in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative the Administration Costs; (4) the Class Representative EnhancementEnhancement Payment; and (5) the PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims who do not opt out of the Eligible Aggrieved EmployeesSettlement. b. If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant Defendants to pay the Gross Settlement Amount Total Consideration or any amounts that otherwise would have been owed under this Agreement. Further, should this occurexcept that Defendants shall pay fifty percent (50%) of the Administration Costs, and Plaintiff shall pay the Parties agree they shall be equally responsible for remaining fifty percent (50%) of the Settlement Administrator's Administration Costs through that dateCosts. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement Payment, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Upon expiration of the Objection/Exclusion Deadlines, Class Counsel will file unopposed motions and memoranda memorandums in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative the Administration Costs; (4) the Class Representative EnhancementEnhancement Payment; and (5) the PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims who do not opt out of the Eligible Aggrieved EmployeesSettlement. b. If the Court denies does not grant Final Approval of the Settlement with prejudiceSettlement, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void, but remains protected by California Evidence Code Section 1152. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Maximum Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occurexcept that Defendant shall pay fifty percent (50%) of the Administration Costs, and Plaintiff shall pay the Parties agree they shall be equally responsible for remaining fifty percent (50%) of the Settlement Administrator's Administration Costs through that dateCosts. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for thethe Class Representative Enhancement Payment, the Attorney Fee Award, and/or the Cost Award, will not constitute a material modification to the Settlement within the meaning of this paragraph. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.and

MOTION FOR FINAL APPROVAL. If the Settlement is preliminarily approved by the Court, the Parties shall thereafter request that the Court enter a Final Approval Order, which grants final approval of the Settlement and enters judgment thereon, and includes the following provisions: a. Finally approving the Settlement and determining the terms thereof to be fair, reasonable, just, adequate, and in the best interests of the Settlement Class Members; b. Confirming certification of the Class for settlement purposes only; c. Directing the Parties to implement and carry out the terms and provisions of the Settlement; d. Finding that the dissemination of the Class Notice in the form and manner ordered by the Court was accomplished as directed, and met the requirements of due process; e. Finally approving Class Counsel’s application for an award of Attorneys’ Fees and Costs; f. Awarding Settlement Administration Costs to the Settlement Administrator; g. Awarding the Service Award to the Class Representative; h. Resolving and settling all the Released Claims by the Class Representative and all Settlement Class Members, as herein above provided, with the release precluding them from instituting, commencing, or continuing to pursue, directly or indirectly, as an individual or collectively, representatively, derivatively, or on behalf of himself or herself, or in any other capacity of any kind whatsoever, any action in this Court, any other state court, or any arbitration or mediation proceeding or any other similar proceeding, against any of the Released Parties, that asserts any Released Claims; i. Releasing, discharging, and fully extinguishing the Released Parties from any and all liability with respect to the Released Class Claims and Released PAGA Claims as hereinabove provided; j. Entering a final judgment that permanently enjoins and bars all Settlement Class Members from reopening or prosecuting any and all of the Released Class Claims and Released PAGA Claims and the Plaintiff’s Released Claims against any of the Released Parties, on satisfaction of all payments and obligations hereunder; and k. Preserving continuing and exclusive jurisdiction over all matters related to the administration and consummation of the terms of this Settlement and enforcement of the Final Approval Order. l. Counsel for Defendant will file unopposed motions and memoranda in support thereof be given an opportunity to comment on the Motion for Final Approval of the Settlement and the following payments in accord supporting papers prior to being filed with the terms of Court, and such comments will be implemented to the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative Enhancement; and (5) PAGA Paymentextent reasonable. Class Counsel will also move provide a draft copy to Defendant for review no later than fourteen (14) calendar days before the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved Employeesfiling date. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff and Class Counsel for the c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After entry of Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes of: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law.

MOTION FOR FINAL APPROVAL. a. Class Counsel will file unopposed motions and memoranda in support thereof for Final Approval of the Settlement and the following payments in accord with the terms of the Settlement: (1) the Attorney Fee Award; (2) the Cost Award; (3) Administrative Costs; (4) the Class Representative EnhancementEnhancement Payments; and (5) PAGA Payment. Class Counsel will also move the Court for an order of Final Approval (and associated entry of Judgment) releasing and barring any Released Claims of the Participating Class Members and the PAGA Released Claims of the Eligible Aggrieved EmployeesClass Members. Defendant agrees that it will not oppose Plaintiffs’ motion for Final Approval of the Settlement so long as the motion is consistent with the terms of the Parties’ Settlement Agreement and that Counsel for Defendant will be provided with sufficient time to review the motion for Final Approval prior to its filing. Plaintiffs’ counsel agrees to share with Counsel for Defendant a draft of the motions and memoranda at least five (5) court days prior to filing each motion. b. If the Court denies Final Approval of the Settlement with prejudice, or if the Court's ’s Final Approval of the Settlement is reversed or materially modified on appellate review, then this Settlement will become null and void. If that occurs, the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount or any amounts that otherwise would have been owed under this Agreement. Further, should this occur, the Parties agree they shall be equally responsible for the Settlement Administrator's ’s Administration Costs through that date. An award by the Court of a lesser amount than sought by Plaintiff Plaintiffs and Class Counsel for thethe Class Representative Enhancement Payments, Attorney Fee Award, Cost Award, and/or Administration Costs will not constitute a material modification to the Settlement. c. Upon Final Approval of the Settlement, the Parties shall present to the Court a proposed Final Approval Order, approving the Settlement and entering Judgment in accordance therewith. After The Effective Final Settlement Date shall operate to permanently bar and enjoin all Participating Class Members (excluding those who submit a valid and timely Exclusion Form) and Class Members from instituting, commencing, prosecuting, or pursuing, either directly or in any other capacity, any of the claims, damages, causes of action, or claims for attorneys’ fees asserted in the Action or identified as Released Claims or PAGA Released Claims in this Agreement. Notwithstanding the entry of Final Judgment in the Action, the Court shall retain jurisdiction to interpret and enforce this Agreement pursuant to Code of Civil Procedure section 664.6. After Judgment, the Court shall have continuing jurisdiction over the Class Action for purposes offor: (1) enforcing this Settlement Agreement; (2) addressing settlement administration matters, and (3) addressing such post-Judgment matters as may be appropriate under Court rules and applicable law. d. Except as to Class Members who timely submit a valid Exclusion Form, the Preliminary Approval Order and Final Judgment will contain provisions enjoining Plaintiffs, Participating Class Members, and the Class Members from prosecuting the claims released herein and enjoining Plaintiffs, Participating Class Members, and the Class Members from initiating or continuing other proceedings regarding the claims released herein, including but not limited to filing any claims for monetary relief of the Released Claims before the Division of Labor Standards and Enforcement (“DLSE”) or in any forum whatsoever. Inclusion of these provisions in the Order of Preliminary Approval Order and Final Judgment and Order of Final Approval is a material part of the consideration for this Settlement. After approval of this Agreement at the Final Approval Hearing and upon funding the Gross Settlement Amount, the Participating Class Members, Class Members, and the Class Representatives each release the Released Parties, and each of them, of and from any and all of the Released Claims and PAGA Released Claims.