14. How will the lawyers be paid?
In contrast to other cases in the past, where plaintiffs’ counsel received about 33% of the recovery, Plaintiffs’ Co-Lead Counsel are requesting to be paid 20% of the amount awarded to each Class Member under the Settlement (i.e., if the Class Member’s claim is for one hundred dollars ($100), the Class Member will receive eighty dollars ($80) and Plaintiffs’ Co-Lead Counsel will receive twenty dollars ($20)) for attorneys’ fees and out-of-pocket expenses for time and expenses incurred in prosecuting this case and estimated time and expenses through the final implementation of this Settlement Agreement. This reduction was made possible because Behr agreed to pay a portion of the fees and costs (in the amount of one million five hundred thousand dollars ($1,500,000)) separate from the amounts to be paid to the class.
Plaintiffs are asking that the Court award each Plaintiff between $1,000 and $2,000 for their time invested in connection with the Actions and securing the benefits of this Settlement for the Class. The Court may award less than these amounts.