Unique Insurance Will Pay $390,000.00 as the Gross Settlement Amount (Gross Settlement)<\/u>. Unique Insurance has agreed to deposit the Gross Settlement into an account controlled by the Administrator of the Settlement. The Administrator will use the Gross Settlement to pay the Individual Class Payments, Class Representative Service Payment, Class Counsel’s attorney’s fees and expenses, and the Administrator’s expenses. Assuming the Court grants Final Approval, Unique Insurance will fund the Gross Settlement not more than [14] days after the Judgment entered by the Court becomes final. The Judgment will be final on the date the Court enters Judgment, or a later date if Participating Class Members object to the proposed Settlement or the Judgment is appealed.
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Court Approved Deductions from Gross Settlement<\/u>. At the Final Approval Hearing, Plaintiff and\/or Class Counsel will ask the Court to approve the following deductions from the Gross Settlement, the amounts of which will be decided by the Court at the Final Approval Hearing.
- A. Up to $40% of the Gross Settlement to Class Counsel for attorneys’ fees and up to $10,000 for their litigation expenses. To date, Class Counsel have worked and incurred expenses on the Action without payment.<\/li>
- B. Up to $10,000 as a Class Representative Award for filing the Action, working with Class Counsel and representing the Class. A Class Representative Award will be the only monies Plaintiff will receive other than Plaintiff’s Individual Class Payment.<\/li>
- C. Up to $35,000 to the Administrator for services administering the Settlement.
  
  Participating Class Members have the right to object to any of these deductions. The Court will consider all objections.
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- Net Settlement Distributed to Class Members<\/u>. After making the above deductions in amounts approved by the Court, the Administrator will distribute the rest of the Gross Settlement (the “Net Settlement”) by making Individual Class Payments to Participating Class Members based on their payments to Unique Insurance.
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- Need to Promptly Cash Payment Checks<\/u>. The front of every check issued for Individual Class Payments will show the date when the check expires (the void date). If you don’t cash it by the void date, your check will be automatically cancelled, and the monies will irrevocably lost to you because they will be paid to a non-profit organization or foundation (“Cy Pres”).
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- Requests for Exclusion from the Class Settlement (Opt-Outs)<\/u>. You will be treated as a Participating Class Member, participating fully in the Class Settlement, unless you notify the Administrator in writing, not later than 30 days, that you wish to opt-out. The easiest way to notify the Administrator is to send a written and signed Request for Exclusion by the SEPTEMBER 21, 2026<\/strong><\/u>, Response Deadline. The Request for Exclusion should be a letter from a Class Member or his\/her representative setting forth a Class Member’s name, present address, telephone number, and a simple statement electing to be excluded from the Settlement. Excluded Class Members (i.e., Non-Participating Class Members) will not receive Individual Class Payments, but will preserve their rights to personally pursue a separate claim against Unique Insurance.
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- The Proposed Settlement Will be Void if the Court Denies Final Approval<\/u>. It is possible the Court will decline to grant Final Approval of the Settlement or decline enter a Judgment. It is also possible the Court will enter a Judgment that is reversed on appeal. Plaintiff and Unique Insurance have agreed that, in either case, the Settlement will be void, will not pay any money and Class Members will not release any claims against Unique Insurance.
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- Administrator<\/u>. The Court has appointed a neutral company Angeion Group (the “Administrator”) to send the Notice, calculate and make payments, and process Class Members’ Requests for Exclusion. The Administrator will also decide Class Member Challenges regarding mail and re-mail settlement checks and tax forms and perform other tasks necessary to administer the Settlement. The Administrator’s contact information is contained in Section 9<\/strong><\/a> of the FAQs.
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- Participating Class Members’ Release<\/u>. After the Judgment is final and Unique Insurance has fully funded the Gross Settlement and separately paid all employer payroll taxes, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Unique Insurance or based on the Class Period facts, as alleged in the Action and resolved by this Settlement.
  
  The Participating Class Members will be bound by the following release:
  
  All Participating Class Members, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, release Released Parties from any and all claims, demands, debts, liabilities, actions, causes of action of every kind and nature, obligations, damages, losses, and costs, whether known or unknown, actual or potential, suspected or unsuspected, direct or indirect, contingent or fixed, that have been, could have been, or in the future might be asserted that arise out of or relate to the allegations of the Action (the “Released Claims”). “Released Claims” do not include any failure by any Party hereto to fully comply with the terms of this Agreement. Nothing herein shall be construed as releasing any claim not related to the Action.<\/li> <\/ol>