STIPULATION AND PROPOSED ORDER

LAWRENCE J. O'NEILL, Chief District Judge.

On November 2, 2015, the Court approved the Consent Decree in this action, which includes a procedure by which plaintiffs collect payment for attorneys' fees and costs incurred in connection with the Consent Decree. Although the Court's Order dismissed the action, the Court specifically retained "continuing jurisdiction to interpret, implement and enforce the settlement, and all orders and judgement entered in connection therewith." Order at 3 [Dkt. No. 179].

Pursuant to the Consent Decree, the defendants have, for the first three years of the remedial phase, paid a flat fee of $40,000 per year to plaintiffs for fees and costs incurred in the remedial phase of this action, delivered at the beginning of each monitoring year following approval of the Consent Decree. Recognizing that plaintiffs' monitoring work in this remedial phase has been more encompassing than the parties had reasonably anticipated, the parties now agree that, within 60 days of the beginning of the fourth monitoring year, defendants shall deliver payment of $60,000 for plaintiffs' fees and costs. In subsequent monitoring years, defendants shall deliver to plaintiffs $18,750 on a quarterly basis for the duration of the Consent Decree, within 30 days of each calendar quarter of monitoring.

WHEREFORE, defendants agree to pay plaintiffs' counsel

I, Alison Hardy, attest that Dan Cederborg signed this document on September 24, 2018.

IT IS SO ORDERED.