How much will Settlement Class Counsel be paid, and how will they be paid?
At the Fairness Hearing, Settlement Class Counsel will ask the Court to approve payment of attorneys fees equal to thirty percent (30%) of the Settlement Fund. The Court may approve this amount, or a lower amount. Settlement Class Counsel will also ask the Court for reimbursement out of the Settlement Fund of the out-of-pocket costs and expenses they have paid and will pay in the lawsuit. To date, Settlement Class Counsel has paid costs and expenses in excess of $1.75 million and expect that additional costs will be paid prior to the Courts approval of the Settlements. In return for the Settlement Class Representatives contributions to the lawsuit, including production of business records, appearances for multiple depositions and otherwise bearing the burdens of assisting in the prosecution of this lawsuit which contributions Settlement Class Counsel believe to be substantial and valuable the Settlement Class Representatives intend to ask the Court for an incentive award not to exceed
