Lime Rock will pay the sum of $1,700,000.00 (subject to adjustments set forth in the Settlement Agreement) to the Settlement Class as a full, complete, and final settlement of all Released Claims as to all Released Parties during the Released Period, as those terms are more specifically defined in the Settlement Agreement. Lime Rock shall not be liable to the Settlement Class, the Class Representative, or Settlement Class Counsel for any other costs, expenses or fees.
Lime Rock and the Class Representative agree that the Settlement Proceeds, subject to adjustments for opt-outs and exclusions from the Class, shall be for the benefit of the Settlement Class, subject only to the court approved Class Counsel Fees and Expenses and Administration Expenses.
When Lime Rock deposits the Settlement Proceeds into the Nash Trust Settlement Account, the Settlement Class and Class Representative shall be deemed to have fully, finally, and forever released, relinquished and discharged Lime Rock and the Released Parties for all Released Claims, again as those terms are defined in the Settlement Agreement.
Lime Rock has asserted and continues to assert many defenses to the Class Representative's and Settlement Class' claims and contentions. Lime Rock expressly asserts its defenses have merit and that it has no liability to the Settlement Class or the Class Representative.