Common use of Plaintiff’s Responsibilities Clause in Contracts

Plaintiff’s Responsibilities. Plaintiff will prepare and deliver to Defense Counsel all documents necessary for obtaining Preliminary Approval reasonably in advance of fding, including: (i) a draft of the notice, and memorandum in support, of the Motion for Preliminary Approval that includes an analysis of the Settlement; (ii) a draft proposed Order Granting Preliminary Approval; (iii) a draft proposed Class Notice; (iv) a signed declaration from the Administrator attaching its estimate for administering the Settlement and attesting to its willingness to serve; competency; and operative procedures for protecting the security of Class Data; (v) a signed declaration from Class Counsel firm attesting to their competency to represent the Class Members and all facts relevant to any actual or potential conflict of interest with Class Members, and/or the Administrator.

Plaintiff’s Responsibilities. Plaintiff will prepare and deliver to Defense Counsel all documents necessary for obtaining Preliminary Approval reasonably in advance of fdingApproval, including: (i) a draft of the notice, and memorandum in support, of the Motion for Preliminary Approval that includes an analysis of the SettlementSettlement under Dunk/▇▇▇▇▇▇; (ii) a draft proposed Order Granting Preliminary Approval; (iii) a draft proposed Class Notice; (iv) a signed declaration from the Administrator attaching its estimate “not to exceed” bid for administering the Settlement and attesting to its willingness to serve; competency; and operative procedures for protecting the security of Class Data; (v) a signed declaration from Class Counsel firm attesting to their competency to represent the Class Members and amounts of insurance coverage for any data breach, defalcation of funds or other misfeasance; all facts relevant to any actual or potential conflict conflicts of interest with Class Members; and the nature and extent of any financial relationship with Plaintiff, and/or the AdministratorClass Counsel or Defense Counsel.