LifeLock 2015 Annual Report Download - page 208

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 50 of 289
shall cooperate in requesting that the Court set a new scheduling order such that neither Party’s substantive or procedural rights is
prejudiced by the attempted Settlement;
D. The Released Parties, as defined herein, expressly and affirmatively reserve all defenses, arguments, and
motions as to all claims that have been or might later be asserted in the Action, including, without limitation, LifeLock’s argument that
the Action may not be litigated as a class action;
E. Plaintiffs and all other Class Members, on behalf of themselves and their heirs, assigns, executors,
administrators, predecessors, and successors, expressly and affirmatively reserve and do not waive any motions as to, and arguments
in support of, all claims, causes of actions, or remedies that have been or might later be asserted in the Action including, without
limitation, any argument concerning class certification, consumer fraud, and damages;
F. This Settlement Agreement, the fact of its having been made, the negotiations leading to it, any informal
discovery or action taken by a Party or Class Member pursuant to or in connection with this Settlement Agreement, or any documents
or communications pertaining to this Settlement Agreement shall not be admissible or entered into evidence for any purpose
whatsoever in the Action or in any other proceeding between the Parties, other than to enforce the terms of this Settlement Agreement;
provided, however, that LifeLock may rely on such evidence to defend itself in any other action not brought on behalf of the Class
and relating to the subject matter of this Action
G. All reasonable Administrative Costs incurred and approved but not yet paid will be paid by LifeLock.
Plaintiffs, Class Counsel, and LifeLock’s Counsel shall not be responsible for any of these costs or any other Settlement-related costs;
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