Extract to table

All capitalized terms not defined herein shall have the meanings ascribed to them in the Policy unless otherwise indicated

This decision shall not be construed as a waiver of Pemberton's rights under the Penalty Exclusion (§ IV

Pemberton expressly reserves all of its rights under the Penalty Exclusion for all other purposes, and this letter shall not be cited as precedent or evidence of Pemberton's willingness to cover PAGA penalties or any other statutory penalties in any other context

The Final Approval Order must be entered on terms that are substantively consistent with the Settlement Agreement as executed on September 15, 2023, and must constitute a final, appealable order disposing of all claims in the consolidated action

The release must be sufficient to preclude any future litigation by participating class members against AMA arising from the conduct at issue during the class period

The material terms of the Settlement Agreement—including without limitation the Gross Settlement Amount, the class definition, the class period, the scope of the release, and the PAGA allocation—shall not be materially modified, amended, or supplemented without Pemberton's prior written consent