An elector may choose to pay off the indebtedness according to any schedule that is suitable to the elector, or may choose, upon retirement, to have his or her retirement benefit actuarially adjusted to reflect the indebtedness. However, all service must be fully paid to be considered for vesting or service-eligible retirement requirements. The parties will cooperate in the drafting of notices and other documents that must be distributed. Defendants agree that this lawsuit is a proper class action under Alaska Rule of Civil Procedure 23, that the class is properly defined in the Class Action Complaint, and that plaintiffs and their counsel can fairly and adequately represent the interests of the class. The parties have entered into this Settlement Agreement solely to terminate all controversies regarding the matters settled and compromised, and to avoid the expense, inconvenience and uncertainty of further litigation.
Defendants expressly deny any liability whatsoever to the plaintiffs.
Plaintiffs' compromises herein do not constitute an admission of the correctness of any of defendants' positions in this litigation. This notice has been approved by counsel for all parties and by the court. R. Weeks Superior Court Judge 6th Fl.