LifeLock 2015 Annual Report Download - page 212

Case 3:15-cv-00258-HSG Document 49-1 Filed 11/04/15 Page 54 of 289
allegations involved in the action; and (iii) the general terms of the Settlement, including the Settlement Fund of Sixty-eight Million
Dollars ($68,000,000.00).
122. Within one hundred and eighty (180) days after the Final Settlement Date (unless the time is extended by written
agreement of the Parties), Class Counsel, any Plaintiffs’ Counsel, and any expert or other consultant employed by them in such
capacity or any other individual with access to documents provided by LifeLock to Class Counsel, shall either: (i) return to
LifeLock’s Counsel all such documents and materials (and all copies of which documents in whatever form made or maintained)
informally produced by LifeLock in the Action and any and all handwritten notes summarizing, describing, or referring to such
documents; or (ii) certify to LifeLock’s Counsel that all such documents and materials (and all copies of such documents in whatever
form made or maintained) informally produced by LifeLock in the Action and any and all handwritten and/or electronically recorded
notes summarizing, describing, or referring to such documents have been destroyed; provided, however, that this Section shall not
apply to any documents made part of the record in connection with a Claim, nor to any documents made part of a Court filing, nor to
Class Counsel’s work product. LifeLock’s Counsel agrees to hold all documents returned by Class Counsel and any expert or other
consultant or any other individual employed by Class Counsel in such capacity with access to documents provided by LifeLock until
two years after the Payment Date.
XX. 
123. The Parties, their successors and assigns, and their counsel agree to use reasonable efforts with one another in
seeking Court approval of this Settlement Agreement and to implement the terms of this Settlement and to use reasonable efforts to
resolve any disputes
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