[Proposed] ORDER GRANTING MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

SUSAN ILLSTON, Senior District Judge.

The parties to the above-captioned litigation (the "Litigation") have entered into a Settlement Agreement and Release of Claims, together with exhibits (collectively, the "Settlement Agreement" or "Settlement"), that sets forth the terms and conditions for a proposed settlement, which if approved by the Court, would fully and finally resolve the Litigation.

Plaintiffs have filed a motion for preliminary approval of the Settlement Agreement and for an order directing dissemination of notice of class action settlement ("Motion"). The Motion came on for hearing on May 13, 2016, at 10:00 a.m. before the undersigned.

Having considered the Motion and the points and authorities and declarations submitted in support of the Motion, including the Class Action Settlement and Release and exhibits, and the notice of class action settlement, and the statements of counsel at the hearing on the Motion and GOOD CAUSE appearing, IT IS HEREBY ORDERED that the Motion is GRANTED, and the Court makes the following findings and orders:

1. This Order incorporates by reference the definitions in the Settlement Agreement, found as Exhibit 2 to the Second Supplemental Declaration of Tomas E. Margain in Support of the Motion for Preliminary Approval [Docket No. 152] and all terms in this Order shall have the same meaning as set forth in the Settlement Agreement.

2. The class action settlement set forth in the Settlement Agreement, entered into among the Parties and their counsel, is preliminarily approved as it appears to be proper, to fall within the range of reasonableness, to be the product of arm's-length and informed negotiations, to treat all Class Members fairly, and to be presumptively valid, subject only to any objections that may be raised at or before the final approval hearing.

3. The Court finds that Plaintiffs' counsel conducted sufficient investigation and research, and that they were able to reasonably evaluate the position of Plaintiffs and class members and the strengths and weaknesses of their claims. Plaintiffs have provided the Court with enough information about the nature and magnitude of the claims being settled, as well as the impediments to recovery, to make an independent assessment of the reasonableness of the terms to which the parties have agreed.

4. The Court also finds that settlement now will avoid additional and potentially substantial litigation costs, as well as delay and risks if the Parties were to continue to litigate the Action.

5. The Court preliminarily approves the Settlement Agreement, including all the terms and conditions set forth therein and the class settlement amount and allocation of payments to Class Members.

6. The rights of any potential dissenters to the proposed Settlement are adequately protected in that they may exclude themselves from the Settlement and proceed with any alleged claims they may have against Defendant, or they may object to the Settlement and appear before this Court. However, to do so they must follow the procedures outlined in the Settlement Agreement and Notice of Class Action Settlement. Failure to follow the procedures outlined in the Settlement Agreement and Notice of Class Action Settlement for making objections shall result in waiver and the objector shall be foreclosed from challenging any of the terms of the Settlement.

7. The Court approves, as to form and content, the proposed Notice of Class Action Settlement ("Class Notice") found at Exhibit 2 of the 2 Second Supplemental Declaration of Tomas E. Margain in Support of Preliminary Approval. The Notice shall be translated by a Tagalog translator hired by the Third Party Administrator CPT Group.

8. The Court hereby appoints CPT Group as the Third Party Claims Administrator.

9. The Court approves the proposed payouts as contained in Exhibit 2 of the Supplemental Declaration of Tomas E. Margain in Support of Preliminary Approval. Docket No. 149 CPT Group is directed to use these amounts to determine payments, payroll tax, and apportion any excess funds in a pro-rate basis among the 42 class members.

10. The Court directs the mailing by the Third Party Claims Administrator, by First-Class U.S. mail, of the Class Notice to Class Members in accordance with the schedule set forth below and the other procedures described in the Settlement Agreement. The Court finds that the method selected for communicating the preliminary approval of the Sett lement Agreement to Class Members is the best notice practicable under the circumstances, constitutes due and sufficient notice to all persons entitled to notice, and thereby satisfies due process.

11. All further proceedings are hereby stayed except for any that are required to effectuate the Settlement Agreement.

12. The following dates shall govern for purposes of this Settlement:

The Court expressly reserves the right to continue or adjourn the final approval hearing from time to time without further notice to the Class Members.

IT IS SO ORDERED.