"f. “Final Non-appealable Judgment” means the judgment of the Court after (1) any
and all appeals to the U.S. Court of Appeals for the D.C. Circuit (the “Court of Appeals”) have been adjudicated, or the time for appeal to the Court of Appeals has expired with no appeal having
been taken, (2) any and all petitions for writ of certiorari to the U.S. Supreme Court (the “Supreme
Court”) have been adjudicated, or the time for filing petitions for writ of certiorari has expired with
no petition having been filed, and (3) if any petition for writ of certiorari is granted, any and all
appeals to the Supreme Court have been adjudicated."
"k. “Total Plaintiffs’ Award” means the sum of all damages and interest awarded during
the trial of the claims in this matter and post-trial proceedings, and allowed after Defendants’ appeal
(or after the expiration of time allowed for filing such appeal, if no appeal is filed within that time),
inclusive of attorneys’ fees, non-taxable litigation expenses, and pre- and post-judgment interest as have been or may be awarded to Plaintiffs, and inclusive of any interest earned through such
investments as the Court may direct following Defendants’ payment of the judgment."
"m. “Net Class Award” means the Total Plaintiffs’ Award less: (i) service awards, if
any, to the representative Plaintiffs; (ii) attorneys’ fees and litigation expenses awarded to Class
Counsel; (iii) compensation and expenses paid or reimbursed to the Distribution Administrator;
(v) any additional administrative expenses that may be charged against the Total Plaintiffs’ Award
at the Court’s direction; and (vi) the Net Berkley Award.
n. “Fannie Preferred Net Class Award” means the portion of the Net Class Award to
be allocated to the Fannie Preferred Class.
o. “Freddie Preferred Net Class Award” means the portion of the Net Class Award to
be allocated to the Freddie Preferred Class.
p. “Freddie Common Net Class Award” means the portion of the Net Class Award to
be allocated to the Freddie Common Class.
q. “Net Berkley Award” means the portion of the Total Plaintiffs’ Award to be
allocated to the WR Berkley Plaintiffs."
