To Plaintiffs. Class Representative Service Payment to the Class Representatives of not more than Ten Thousand Dollars ($10,000.00) each (in addition to any Individual Class Payment and any Individual PAGA Payment the Class Representative is entitled to receive as a Participating Class Member). Freedom will not oppose Plaintiffs’ request for a Class Representative Service Payment that does not exceed this amount. As part of the motion for Class Counsel Fees Payment and Class Litigation Expenses Payment, Plaintiffs will seek Court approval for any Class Representative Service Payments no later than 16 court days prior to the Final Approval Hearing. If the Court approves a Class Representative Service Payment less than the amount requested, the Administrator will retain the remainder in the Net Settlement Amount. The Administrator will pay the Class Representative Service Payment using IRS Form 1099. Plaintiffs assume full responsibility and liability for employee taxes owed on the Class Representative Service Payment.
To Plaintiffs. Plaintiffs, through Class Counsel, will seek the Court’s approval, as part of its motion for final approval of the Agreement, of an amount not to exceed $40,000 in total for Class Representative Service Awards. Payments made pursuant to this Section shall be made within twenty (20) business days of the Effective Date, care of Class Counsel, who shall distribute the entire amount among Plaintiffs according to their involvement in the Litigation. Plaintiffs, Class Counsel, and Defendants negotiated and agreed to the amount of the Class Representative Service Award only after reaching agreement in principle on all material terms of consideration for the Settlement Class.
To Plaintiffs. In addition to the Settlement Shares to be paid to Plaintiffs, Plaintiffs will apply to the Court for an award of not more than $10,000 each as Class Representative Service Payments, which is combined total of $20,000 in Class Representative Service Payments. Defendant will not oppose Class Representative Service Payments of no more than $10,000 for each of the Plaintiffs. The Settlement Administrator will pay the Class Representative Service Payments approved by the Court out of the Gross Settlement Amount. If the Court approves a Class Representative Service Payments of less than $10,000, for each of the Plaintiffs, the remainder will be retained in the Net Settlement Amount for distribution to Participating Class Members. Payroll tax withholding and deductions will not be taken from the Class Representative Service Payments and instead a Form 1099 will be issued to each of the Plaintiffs with respect to the payments who will assume full responsibility and liability for the taxes due on their Class Representative Service Payments.
To Plaintiffs. In addition to their Settlement Shares, Plaintiffs will apply to the Court for a Class Representative Service Payment from the Total Settlement Amount of not more than $7,500 for Xxxxx Xxxx, the named plaintiff, and $2,500 for Xxxxx Xxxxxxx, the opt-in plaintiff, in consideration of their initiating and pursuing the Action and undertaking the risk of prosecution of the Action. TPMG will not oppose a Class Representative Service Payment of not more than $7,500 for Xxxxx Xxxx and $2,500 for Natty Xxxxxxx. The Settlement Administrator will pay the Class Representative Service Payments approved by the Court (but not more than $7,500 for Xxxxx Xxxx and $2,500 for Natty Xxxxxxx) out of the Total Settlement Amount. If the Court approves a Class Representative Service Payment of less than $7,500 for Xxxxx Xxxx and $2,500 for Natty Xxxxxxx, the remainder for each Plaintiff will be retained in the Net Settlement Amount. Tax deductions and withholdings will not be taken from the Class Representative Service Payments, and instead a Form 1099 will be issued to each Plaintiff with respect to this payment. Plaintiffs will provide a completed Form W-9 to the Settlement Administrator before the payment is made.
To Plaintiffs. In addition to their Settlement Shares, Plaintiffs will apply to the Court for incentive awards of not more than $5,000 to each of them as their Class Representative Payments. Defendant will not oppose Class Representative Payments of $5,000 to each Plaintiff. The Settlement Administrator will pay the Class Representative Payments approved by the Court out of the Gross Settlement Amount. If the Court approves Class Representative Payments of less than $5,000 to each Plaintiff, the remainder will be retained in the Net Settlement Amount. A Form 1099 will be issued to Plaintiffs with respect to their Class Representative Payments.
To Plaintiffs. Class and PAGA Representative Service Payment to Class Representative Xxxxx Xxxxxx and PAGA Representative Xxxxxxx Xxxxx of not more than $2,500.00 each (in addition to any Individual Class Payment and any Individual PAGA Payment the Class Representative and PAGA Representative are entitled to receive as a Participating Class Member or PAGA Member). Defendant will not oppose Plaintiffs’ request for a Class and PAGA Representative Service Payment that does not exceed this amount. As part of the motion for Class/PAGA Counsel Fees Payment and Class Litigation Expenses Payment, Plaintiffs will seek Court approval for any Class and PAGA Representative Service Payments no later than 16 court days prior to the Final Approval Hearing. If the Court does not approve, or approves a Class and PAGA Representative Service Payment less than the amount requested, the Administrator will retain the remainder in the Net Settlement Amount. The Administrator will pay the Class and PAGA Representative Service Payment using IRS Form 1099. Plaintiffs assume full responsibility and liability for employee taxes owed on the Class and PAGA Representative Service Payment.
To Plaintiffs. Plaintiffs, through Class Counsel, will request Class Representative Service Awards totaling no more than $30,000 (or a maximum of $5,000 per class representative). Payments made pursuant to this Section shall be made within twenty (20) business days of the Effective Date, care of Class Counsel. Plaintiffs, Class Counsel, and Defendants negotiated and agreed to the amount of Class Representative Service Award, by and through the Mediator, only after reaching agreement in principle on the material terms of consideration for the Settlement Class.
To Plaintiffs. Class Representative Service Payment to each proposed Class Representative of not more than $5,000.00 (in addition to any Individual Class Payment and any Individual PAGA Payment the Class Representative is entitled to receive as a Participating Class Member). JBT will not oppose Plaintiffs’ request for a Class Representative Service Payment that does not exceed this amount. As part of the motion for Class Counsel Fees Payment and Class Litigation Expenses Payment, Plaintiffs will seek Court approval for any Class Representative Service Payments no later than 16 court days prior to the Final Approval Hearing. If the Court approves a Class Representative Service Payment less than the amount requested, the Administrator will retain the remainder in the Net Settlement Amount. The Administrator will pay the Class Representative Service Payment using IRS Form 1099. Plaintiffs assume full responsibility and liability for employee taxes owed on the Class Representative Service Payment. Proposed Class Representatives understand that Service Payments to class representatives are discretionary, and there is no presumption of fairness in reviewing them. (Xxxxx v. Dick's Sporting Goods, Inc., 238 Cal. App. 4th 1251, 1272).
To Plaintiffs. In addition to their Settlement Shares, Plaintiffs will apply to the Court for a Class Representative Service Payment from the Total Settlement Amount of not more than $15,000 (to be allocated in the amount of $7,500 to Xxxxx Xxxxxxx and $7,500 to Jewel Xxxxxx Key) in consideration of their initiating and pursuing the Action and undertaking the risk of prosecution of the Action. AxisPoint will not oppose a total Class Representative Service Payment of not more than $15,000. The Settlement Administrator will pay the Class Representative Service Payments approved by the Court out of the Total Settlement Amount. If the Court approves a Class Representative Service Payment of less than $7,500 for Xxxxx Xxxxxxx and $7,500 for Jewel Xxxxxx Key, the remainder for each Plaintiff will be retained in the Net Settlement Amount. Tax deductions and withholdings will not be taken from the Class Representative Service Payments, and instead a Form 1099 will be issued to each Plaintiff with respect to this payment. Plaintiffs will provide a completed Form W-9 to the Settlement Administrator before the payment is made.
To Plaintiffs. In addition to the Settlement Shares, Plaintiffs will apply to the Court for an award of not more than $15,000 each as Class Representative Service Payments to Xxxxxxx Xxxxxx, Xxxxxx Xxxxx, Xxxxx Xxxx, Xxxx Xxxxxx Xxxxxxxx and an award of not more than $10,000 as a Class Representative Service Payment to Xxxxxxx Xxxxxxxx. Defendant will not oppose Class Representative Service Payments in these amounts. The Settlement Administrator will pay the Class Representative Service Payment approved by the Court for Xxxxxxx Xxxxxx and Xxxxxxx Xxxxxxxx out of the Xxxxxx Settlement Amount. The Settlement Administrator will pay the Class Representative Service Payments approved by the Court for Xxxxxx Xxxxx, Xxxxx Xxxx, Xxxx Xxxxxx Xxxxxxxx out of the Xxxxx/Xxxx Settlement Amount. If the Court approves Class Representative Service Payments for less than the amounts set forth above to each of the Plaintiffs, the remainder will be retained in the applicable Net Xxxxxx Settlement Amount or Net Xxxxx/Xxxx Settlement Amount for distribution to Participating Class Members. Payroll tax withholding and deductions will not be taken from the Class Representative Service Payments and instead a Form 1099 will be issued to the Plaintiffs with respect to the payment. To receive the payment, the Plaintiffs agree to a 1542 waiver and a general release of all claims as set forth herein below.
