SETTLEMENT APPROVAL PROCEDURE Clause Samples

SETTLEMENT APPROVAL PROCEDURE. (a) This Settlement Agreement will become final and effective upon occurrence of all of the events required to obtain the Effective Date. The Parties and their counsel agree to use their best efforts to obtain a final court order approving this Settlement (“Final Approval Order”). (b) Promptly upon execution of this Settlement Agreement by the Parties and their respective counsel of record, the Named Plaintiffs shall submit the following to the Court for approval a Motion for Preliminary Approval of the Settlement as described in Sections III.9 of this Agreement for purposes of effectuating this Settlement. (c) The document described in subsection (b) above shall seek the following order(s) from the Court, among other orders detailed in this Agreement or agreed upon by the Parties: (1) the entry of an order by the Court granting preliminary approval of the Settlement Agreement, including conditional certification of the Class for settlement purposes only (the Parties’ proposed Order Granting Preliminary Approval is attached hereto as “Exhibit B”); (2) the entry of an order by the Court approving the proposed Notice(s), the proposed and agreed upon form(s) of which are attached hereto as Exhibit A; and (3) the entry of an order by the Court scheduling a hearing date for final approval of the Settlement Agreement. (d) After the Order Granting Preliminary Approval is Granted, the Parties will seek Final Approval of the Settlement as detailed in this Settlement. As part of this process, Class Counsel shall file, on or before the date of the final approval hearing, the documents detailed in this Settlement, including but not limited to the Claims Administrator’s verification, in writing, that the Notice to the Class has been disseminated in accordance with the Court’s Order Granting Preliminary Approval.

SETTLEMENT APPROVAL PROCEDURE. On or before fourteen (14) days1 after full execution of this Agreement, the Named Plaintiff shall file an Unopposed Motion for Order Approving Settlement of Collective Action and Authorizing Notice of Settlement and Opportunity to File Consent to Join and Release Forms, and Dismissal with Prejudice (“Approval Motion”) with this Settlement Agreement, the Notice of Settlement (to reflect the Named Plaintiff's and each Potential Opt-In Plaintiff's individual settlement amount and a summary of the basis for settlement) and Consent to Join and Release Form (collectively, the “Notice Packet”), which is attached to this Agreement as Exhibit A, advising the Named Plaintiff and Potential Opt-In Plaintiffs of the material terms and provisions of this settlement, the procedure for submitting Consent to Join and Release Forms, and their rights with respect to this settlement. The Settling Parties shall also submit an agreed- upon Proposed Order (“Approval Order”), which is attached to this Agreement as Exhibit B. Not later than five (5) court days prior to the submission of the Approval Motion, the Named Plaintiff's Counsel will submit a near-final draft thereof to Counsel for ▇▇▇▇▇▇▇ ▇▇▇▇▇ for their review and comment.

SETTLEMENT APPROVAL PROCEDURE. The Settling Parties shall work in good faith to, within ten (10) days1 after the execution of this Agreement, initiate a lawsuit between the Settling Parties in the Fifteenth Judicial Circuit Court in and for Palm Beach County, Florida (the “Litigation”). Thereafter, counsel for Named Plaintiffs shall also file fifteen (15) days after the upon appearance in the Litigation of counsel for Liberty Mutual—to be made within five (5) days of the filing of the Complaint—the Joint Motion for Final Approval of Settlement of Collective Action and Authorization of Notice of Settlement and Opportunity to File Consent to Join Settlement, Release and Claim Form (“Approval Motion”) with the Agreement, along with the agreed-to (proposed) Agreed Order on Joint Motion (“Approval Order”). Counsel for the Named Plaintiffs will also attach to the Motion the Notice of Settlement and the Consent to Join Settlement, Release and Claim Form (collectively, the “Notice Packet”), which is attached to this Agreement as Exhibit A, advising the Potential Claimants of the material terms and provisions of this settlement, the procedure for submitting Consent to Join Settlement, Release and Claim Forms, and their rights with respect to 1 All time periods provided by this Agreement are stated in calendar days, not business days, unless otherwise stated. this settlement. Prior to filing the Approval Motion, counsel for Named Plaintiffs shall send a draft of such motion to counsel for Liberty Mutual for review and comment. Plaintiffs’ Counsel shall send the draft Approval Motion to Liberty Mutual three (3) days after this Agreement is executed. Within three (3) business days of receipt of such draft, Liberty Mutual shall provide comments, if any, to counsel for Named Plaintiffs and thereafter counsel for both parties shall meet and confer to discuss such comments, and counsel for Named Plaintiffs shall incorporate any such agreed upon comments into the Approval Motion before filing it with the court.

SETTLEMENT APPROVAL PROCEDURE. This Settlement Agreement will become final and effective upon occurrence of all of the following events described in this paragraph:

SETTLEMENT APPROVAL PROCEDURE. This Agreement will become final and effective upon occurrence of all of the following events: a. Entry of an Order by the Court granting approval of this settlement; b. Execution of this Agreement by the Named Plaintiffs, the Defendants, and their respective counsel of record; c. Entry of an Order dismissing the case with prejudice; d. The Defendants shall tender to the Settlement Fund the $2,100,000 in 18 monthly equal installments of $116,666.67 payable on the last calendar day of each month commencing on the last day of the first month following an Order approving this settlement which will cover the payments specified in Section 4.

SETTLEMENT APPROVAL PROCEDURE. 68. The Settlement Agreement requires the occurrence of the all of the following events: (a) execution of the Settlement Agreement by the Parties; (b) submission of the Settlement Agreement by the Parties to the Court for preliminary approval; (c) entry of the Preliminary Approval Order by the Court granting preliminary approval of the Settlement Agreement under Rule 23 of the Federal Rules of Civil Procedure and FLSA Section 216(b); (d) Court approval of the method of distribution and the form and content of the Notice of Settlement; and (e) filing by Class Counsel, on or before the date of the Final Approval Hearing, certifying that the Settlement Notice to the Settlement Class has been disseminated in accordance with the Court’s order. 69. The Settlement Agreement will become final and effective only upon the occurrence of the following events: (a) the Court enters the Final Approval Order and Final Judgment; and

SETTLEMENT APPROVAL PROCEDURE. On or before October 11, 2024, the Named Plaintiffs shall file an Unopposed Motion for Order Approving Settlement of Collective Action and Authorizing Notice of Settlement and Opportunity to File Consent to Join and Release Forms (“Approval Motion”) with this Settlement Agreement, the Notice of Settlement (which shall include a summary of the basis for settlement and, after court approval, will reflect each Potential Opt-In Plaintiff’s estimated Individual Gross Settlement Payment) and Consent to Join and Release Form (collectively, with the self-addressed postage prepaid envelope, the “Notice Packet”), which is attached to this Agreement as Exhibit A advising the Potential Opt-In Plaintiffs of the material terms and provisions of this settlement, the procedure for submitting Consent to Join and Release Forms, the URL for a secure interactive website/portal where Potential Opt-In Plaintiffs may submit their Consent to Join and Release, and their rights with respect to this settlement. The Settling Parties shall also submit the agreed-upon Approval Order.

SETTLEMENT APPROVAL PROCEDURE. 15.1. The Parties agree to promptly execute this Settlement Agreement and Plaintiffs shall submit to the Court for approval a Motion for Preliminary Approval of the Settlement for purposes of effectuating this Settlement Agreement. 15.2. The Motion for Preliminary Approval shall seek the following order(s) from the Court: (1) entry of an order by the Court granting preliminary approval of the Settlement Agreement; (2) approval of the Class Notice, and finding that the proposed method of disseminating the Class Notice meets the requirements of due process and is the best notice practicable under the circumstances; and (3) entry of an order by the Court scheduling a hearing date for final approval of the Settlement Agreement.

SETTLEMENT APPROVAL PROCEDURE. 33. The Settlement Agreement requires the occurrence of all of the following events: (a) execution of the Settlement Agreement by the Parties; (b) submission of the Settlement Agreement by the Parties to the Court for approval; (c) entry of an order by the Court granting approval of the Settlement Agreement and certification of a final FLSA collective action of the Potential Opt-In Plaintiffs as defined herein for settlement purposes only; and (d) Court approval of the method of distribution and the form and content of the Notice of Settlement. 34. Within fourteen (14) calendar days of execution of this Settlement Agreement, the Parties shall file with the Court the Approval Motion requesting that the Court: (a) grant approval of the Settlement Agreement described herein; (b) certify a final FLSA collective action of the Potential Opt-In Plaintiffs as defined herein for settlement purposes only; and (c) approve the Notice of Settlement and the proposed plan of settlement administration described herein. Plaintiffs’ Counsel will draft the Approval Motion and will provide it to Facebook’s counsel seven