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will calculate and pay each Class Member's share of the Benefit Amount in <br />accordance with the distribution formula and procedures attached as Exhibit B. <br />4. Within 7 Days after the Effective Date, the Settlement Administrator <br />will pay to each Class Representative a Class Representative Fee of $2,500. <br />5. Q.T. Defendants agree to provide information to Class Counsel and the <br />Settlement Administrator reasonably necessary to implement the settlement, provide <br />notice to potential Class Members, and effect distributions to Class Members. <br />B. Q.T. Defendants will comply with the construction protocols attached as <br />Exhibit C in all future construction work at Pike Lake Apartments and other properties <br />owned, managed, or otherwise controlled by any Q.T. Defendant. <br />C. Within 30 days after the Effective Date, Class Counsel and the appropriate Q.T. <br />Defendants will submit a stipulated motion or motions to the Court requesting the expungement <br />of all eviction actions filed by any Q.T. Defendant against any Class Member in and between the <br />dates of December 10, 2019 and May 31, 2020. Q.T. Defendants cannot be required make any <br />untrue statements in the expungement motion(s). This Settlement Agreement is not contingent <br />on the outcome of the expungement motion(s). <br />D. Within 30 days after the Effective Date, the appropriate Q.T. Defendant(s) will <br />advise in writing any credit agency or debt collection firm to whom a report of debt relating to <br />any Class Member with respect to their tenancy at the Property was given by such Q.T. <br />Defendant that the referenced debt has been satisfied. Such required actions shall include written <br />communications to Hunter Warfield that the debt reported in the name of "Pike Lake Apartments <br />LLC" or other name regarding Plaintiff Acardio Vega and his wife Angelica Villifane has been <br />satisfied, that any indication of debt should be removed from their records, and that any related <br />collection efforts should stop. This Settlement Agreement is not contingent on the outcome of <br />10 <br />