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unless otherwise expressly agreed to in this Settlement Agreement. <br />C. Within 7 Days after the Effective Date, Pike Lake Q, LLC and Calondra <br />Chandler will file a Stipulation of Dismissal and Expungement in the eviction action Pike <br />Lake Q, LLC v. Chandler, Civ. No. 62 -HG -CV -20-425 in Ramsey County Court, State of <br />Minnesota, with each Party to bear his, her, or its own costs, fees, and expenses apart from <br />any agreed upon in this Settlement Agreement. <br />V. PRELIMINARY APPROVAL PROCESS <br />A. Class Counsel will move the Court for a Preliminary Approval Order <br />preliminarily approving the Settlement and the Class Notice Program. The Motion for <br />Preliminary Approval will request that the Court enter an Order: <br />Preliminarily approving this Settlement Agreement. <br />2. Preliminarily certifying the Class. <br />3. Preliminarily approving Class Counsel. <br />4. Preliminarily finding that the proposed Settlement is fair, reasonable <br />and adequate to warrant providing notice to the Class, which notice will: (i) <br />describe the essential terms of the Settlement; (ii) indicate the time and place of the <br />hearing to consider final approval of the Settlement, and the method for objection to <br />and/or opting out of the Settlement; (iii) explain the procedures for allocating and <br />distributing the Settlement Fund; and (iv) prominently display the address of Class <br />Counsel and the procedure for making inquiries. <br />5. Scheduling a Final Approval Hearing for May 5, 2021, or as soon <br />thereafter as the Court can schedule the hearing, to consider the fairness, <br />reasonableness and adequacy of the proposed Settlement and whether it should be <br />finally approved by the Court. <br />12 <br />