Amanda Stevens, on behalf of herself and all others similarly situated, v. Nelnet Servicing LLC

(a) Cash Payments to Class Members. Should this Settlement be fully and finally approved by the Court, Defendant will establish a cash fund in the amount of $325,000 (the “Total Settlement Fund”).

Each Settlement Class Member will receive a flat rate distribution on a per letter basis of the Total Settlement Fund. Only one Settlement payment will be made per Settlement Class Member. The payment will be made payable to the primary borrower listed on the affected account.

After reduction for anticipated administrative costs as well as any attorney’s fees, costs, and service award granted by the Court, the estimated disbursement to each Class Member per letter from the Total Settlement Fund will be $319.12. This estimate assumes all Class Members participate in the Settlement, is merely an estimate and is subject to necessary modifications. Any amounts which remain in the Total Settlement Fund after payment of the amounts described herein will be distributed to a cy pres recipient to be agreed upon by the parties and approved by the Court.

Please understand that these sums may be taxable, that such tax consequences are further described in the Settlement Agreement, and that counsel is not giving you any tax advice. You are encouraged to seek tax advice without delay from a tax professional.

(b) Service Award. The Plaintiff who brought this lawsuit, Amanda Stevens, will request a service award of $7,500.00, for serving as class representative.

(c) Attorney’s Fees and Costs. Class counsel are Klein & Sheridan, LC and Bailey Glasser LLP. They will request attorney’s fees of 33% of the total amount of the Total Settlement Fund, plus litigation costs of $2,006.64.

(d) Opinion of Class Counsel. Class counsel considers it to be in the best interest of the class to enter into this Settlement on the terms described in light of the potential recovery, Defendant’s defenses, and the uncertainties of continued litigation.

(e) Release. Each person who remains in the Settlement Class and receives Settlement benefits will, if the Settlement is approved, provide a release to (1) Defendant Nelnet Servicing LLC; (2) each of Nelnet’s past, present, or future subsidiaries, parent companies, divisions, affiliates, partners or any other organization units of any kind doing business under their names, or doing business under any other names, or any entity now or in the past controlled by, controlling, or under the common control with any of the foregoing and doing business under any other names, and each and all of their respective affiliates and subsidiaries, and each of their respective predecessors, successors, and assigns; and (3) each of the present and former officers, directors, partners, shareholders, agents, employees, attorneys (including any consultants hired by counsel), advisors, independent contractors, representatives, beneficial owners, insurers, accountants, heirs, executors, and administrators, and each of their respective predecessors, successors, and assigns of any person or entities in subparts (1) or (2) hereof. The release shall include any and all actions, causes of action, claims or demands, offsets, setoffs, suits, damages, lawsuits, costs, relief for contempt, losses, attorney’s fees, expenses, or liabilities of any kind whatsoever in law or in equity, for any relief whatsoever, including monetary, sanctions or damage for contempt, injunctive, or declaratory relief, rescission, general, compensatory, special, liquidated, indirect, incidental, consequential, or punitive damages, equitable relief, as well as any and all claims for treble damages, penalties, interest, attorney’s fees, costs, or expenses, whether a known or Unknown Claim (including claims which the debtor does not know or suspect exist in his or her favor at the time of providing the release, which if known by him or her would have materially affected his or her settlement with the creditor), suspected or unsuspected, contingent or vested, accrued or not accrued, liquidated or unliquidated, matured or unmatured, that have been or could have been asserted in any form by Settlement Class Members against Defendant, whether statutory or regulatory violations, negligence, contractual in nature, equitable, or existing under common law and any damages (as set forth above) proximately caused by or otherwise attributable to, directly or indirectly, whether or not currently known, arising out of, based upon or related to the class claims set forth in the Class Action Complaint regarding Defendant’s billing practices and/or the use of administrative forbearances during the pendency of income driven repayment plan applications, and/or the processing of income driven repayment plan applications.

(f) Binding Effect of Class Judgment. Upon conclusion of the Settlement, the judgment of the Court will be binding upon all Class Members who do not opt out of the Settlement.