The Settlement Class. A. The Parties agree, for purposes of this Agreement only, to the following Federal Rule of Civil Procedure 23(b)(1), non-opt-out class: All individuals: (1) who submitted Late-Filing Requests under Section 5(g) of the ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇ Consent Decree on or after October 13, 1999, and on or before June 18, 2008; but (2) who have not obtained a determination on the merits of their discrimination complaints, as defined by Section 1(h) of the Consent Decree. Where used in this Agreement, the “Class” refers, individually and collectively, to the Class Representatives, the Class, and each Member of the Class as well as their heirs, administrators, personal representatives, successors, and/or assigns. B. In accordance with the terms of this Agreement, the Signatory Plaintiffs will move for certification of this Settlement Class, for appointment of some of the Signatory Plaintiffs as the Class Representatives, for appointment of Class Counsel, and for designation of specific counsel from among Class Counsel to serve as Lead Class Counsel and members of the Plaintiffs’ Steering Committee.
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Sources: Settlement Agreement, Settlement Agreement, Settlement Agreement