Class Counsel have prosecuted this case on a contingency basis. They have not received any fees for their services or reimbursement for costs and expenses associated with this case. Class Counsel filed an application with the Court requesting an award of reasonable attorney fees, costs, and expenses in an amount not exceeding a collective combined total sum of $2,500,000. SOA has agreed not to oppose Class Counsel’s Fees and Expenses Application to the extent that it does not exceed that combined total sum, and Class Counsel have agreed not to accept any fees and expenses in excess of that combined total sum.
Class Counsel also applied to the Court for Class Representative service awards, in the amount of $5,000 each, to the Class Representatives James Sampson, Janet Bauer, Lisa Harding, Barbara Miller, Shirley Reinhard, Celeste and Xavier Sandoval (to receive only one award of $5,000 collectively), Danielle Lovelady Ryan, and Elizabeth Wheatley, for their efforts in pursuing this litigation for the benefit of the Settlement Class.
Any award for Class Counsel Fees and Expenses, and any service awards to the Class Representatives, will be paid separately by Defendant and will not reduce any benefits available to you or the rest of the Settlement Class under the Settlement. You won’t have to pay the Class Counsel fees and expenses.
Class Counsel’s Fees and Expenses Application and request for Class Representative service awards was filed on August 22, 2025, and a copy is available for review on the Important Documents page.