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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA
MELODY DANIELS, an individual; on behalf of herself and all others similarly situated,
Plaintiffs, vs.
WORLDWIDE TRACERS, INC., a Texas
Corporation; and DOES 1 through 50, inclusive
Defendants.
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CASE NO.: 1-09-CV-150765
CLASS ACTION
[PROPOSED]
APPROVING
FINAL
CLASS
SETTLEMENT AND
Date: July 27, 2012
Time: 9:00 a.m.
Dept.: 1
ORDER
Judge: Hon. James P. Kleinberg
ACTION
JUDGMENT
On July 27, 2012, this Court heard the Unopposed Motion for Final Approval of Class
21 Action Settlement, an Award of Attorneys' Fees and Costs to Class Counsel, and an Incentive
22 Award to the Class Representative filed by Plaintiff Melody Daniels ("Plaintiff"). This Court
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24 reviewed the motion and the supporting papers, including the Settlement Agreement and Release
("Agreement") previously submitted to this Court, and counsel’s arguments. No objections to
25 the class action settlement were filed or presented to the Court by any Class Member. As such,
26 based on the review of the settlement and the findings below, the Court found good cause to
27 grant the motion.
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[PROPOSED] FINAL ORDER APPROVING CLASS ACTION SETTLEMENT AND JUDGMENT

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1.
The Agreement is fair, reasonable, and adequate.
2.
The parties adequately performed their obligations under the Agreement.
3.
Plaintiff provided notice to Class Members in compliance with Paragraph 3(B) of
5 the Agreement, due process, and California Rules of Court, rules 3.766 and 3.769(f). The notice:
6 (i) fully and accurately informed Class Members about the lawsuit and settlement; (ii) provided
7 sufficient information so that Class Members were able to decide whether to accept the benefits
8 offered, opt out and pursue their own remedies, or object to the proposed settlement;
9 (iii) provided procedures for Class Members to opt out of the proposed settlement, or to file
10 written objections to the proposed settlement and appear at the fairness hearing to state
11 objections to the proposed settlement; (iv) stated that the judgment, whether favorable or not,
12 will bind all Class Members who do not request to opt out; and (v) provided the time, date and
13 place of the fairness hearing and stated that any Class Member who does not opt out may enter
14 an appearance through counsel.
15 An award of $77,600.00 in attorneys' fees and costs to Class Counsel is fair and
16 reasonable in light of the nature of this case, Class Counsel's experience and efforts in
17 prosecuting this Action, and the benefits obtained for the Class.
18 An incentive award to Plaintiff of $1,000.00 is fair and reasonable in light of: (a)
19 Plaintiff's risks (including financial) in commencing this action as the Class Representative; (b)
20 the time and effort spent by Plaintiff in litigating this action as the Class Representative; and (c)
21 Plaintiff's public interest service.
22 IT IS ORDERED AND ADJUDGED THAT:
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Class Members . The Class Members are defined as:
All individuals who, while residing in the State of California, purchased any one of Defendant's services that were advertised as being performed in exchange for a
"flat fee" during the period of time between August 26, 2005 through May 30,
2012.
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[PROPOSED] FINAL ORDER APPROVING CLASS ACTION SETTLEMENT AND JUDGMENT

1 Binding Effect of Order and Judgment . One Class Member, Carol Crist, requested to
2 be excluded from the settlement. As such, this Order and Judgment does not apply to or bind
3 Carol Crist. This Order and Judgment applies to all claims or causes of action settled and
4 released under the Agreement, and binds all Class Members who did not request to be excluded
5 from the settlement.
6 Release . Plaintiff and all Class Members who did not opt out are: (1) deemed to have
7 released and discharged Defendant from all claims arising out of or asserted in this action and all
8 claims released under the Agreement; and (2) barred and permanently enjoined from asserting,
9 instituting, or prosecuting, either directly or indirectly, any and all of these claims.
10 4. Attorneys' Fees and Costs . Class Counsel is awarded $77,600.00 in attorneys'
11 fees and costs. Defendant shall pay Class Counsel these amounts no later than thirty (30) days
12 after the entry of this Final Order and Judgment.
13 5. Incentive Award . Plaintiff is awarded $1,000.00 as an incentive award.
14 Defendant shall pay Plaintiff this amount no later than thirty (30) business days after the entry of
15 this Final Order and Judgment.
16 6. Court's Jurisdiction and Conclusion . The Action is hereby concluded;
17 provided however, and without affecting the finality of this Order and Judgment in any way, that
18 pursuant to the parties' request under Code of Civil Procedure section 664.6, and California
19 Rules of Court, rule 3.769(h), the Court will retain jurisdiction over this action and the parties
20 until final performance of the Agreement.
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DATED: _______________, 2012 ________________________________________
JUDGE OF THE SUPERIOR COURT
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[PROPOSED] FINAL ORDER APPROVING CLASS ACTION SETTLEMENT AND JUDGMENT