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A. "Benefit Amount" means the amount that Class Members will receive as <br />detailed in Section III and payable from the Settlement Fund. <br />B. "City Defendant" means the City of New Brighton, Minnesota. <br />C. "City Defendant Counsel" means the lawyers at Greene Espel PLLP. <br />D. "Class" means all Class Members. <br />E. "Class Member" means any person who rented or resided in an apartment unit <br />at the Property on December 10, 2019, and who does not timely exclude himself or herself <br />(i.e. become an Opt -Out) pursuant to Section VII, Paragraph C.1 <br />F. "Class Counsel" means the lawyers at the Housing Justice Center and <br />Dorsey & Whitney LLP. <br />G. "Class Notice" means the Court -approved form of notice to the Class, which <br />will notify members of the Class of entry of the Preliminary Approval Order and the <br />scheduling of the Final Approval Hearing, among other things, attached as Exhibit A. <br />H. "Class Notice Program" means the process devised by the Parties and the <br />Settlement Administrator, and approved by the Court, for notifying the Class of the Settlement <br />and Settlement Agreement. <br />I. "Class Representative Award" has the meaning set forth in Section VIII, <br />Paragraph B. <br />J. "Class Representatives" means Plaintiffs and Class Members Calondra <br />Chandler, Brian Grieger, Arianna Jackson, and Arcadio Vega. <br />K. "Confidential Information" means the names, phone numbers, account <br />numbers, and other data concerning Class Members relating to this settlement. <br />1 For avoidance of doubt, a person renting a garage at the Property without at the same time <br />renting an apartment unit at the Property is not a Class Member. <br />