United States District Court Eastern District of Arkansas Western Division
Case 4:13-cv-00250-JMM Document 5 Filed 07/16/13 Page 1 of 27 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION ) NATIONAL TRUCKING FINANCIAL ) RECLAMATION SERVICES, LLC, ) BRUCE TAYLOR, EDIS TRUCKING, ) INC., JERRY FLOYD, MIKE CAMPBELL, ) PAUL OTTO, TOWNES TRUCKING, INC. ) Case No. 4:13-cv-00250-JMM and R&R TRANSPORTATION, INC., ) individually, and on behalf of all others ) similarly situated, ) ) Plaintiffs, ) ) vs. ) ) PILOT CORPORATION, PILOT TRAVEL ) CENTERS, LLC D/B/A PILOT FLYING J, ) FJ MANAGEMENT, INC., CVC CAPITAL ) PARTNERS, JAMES A. ―JIMMY‖ ) HASLAM, III, MARK HAZELWOOD, ) MITCH STEENROD, SCOTT WOMBOLD, ) JOHN FREEMAN, VINCENT GRECO and ) BRIAN MOSHER, ) ) Defendants. ) ) DEFENDANTS PILOT CORPORATION AND PILOT TRAVEL CENTERS LLC’S MEMORANDUM IN SUPPORT OF MOTION FOR PRELIMINARY APPROVAL OF CLASS SETTLEMENT AND APPROVAL OF NOTICE TO SETTLEMENT CLASS Defendants Pilot Corporation (f/k/a Pilot Oil Corporation) and Pilot Travel Centers LLC d/b/a Pilot Flying J (collectively, ―Defendants‖ or ―Pilot Flying J‖) submit this memorandum in support of the Joint Motion for Preliminary Approval of Class Settlement and Approval of Notice to Settlement Class Members. Preliminary approval of both is warranted for the reasons set forth below. Case 4:13-cv-00250-JMM Document 5 Filed 07/16/13 Page 2 of 27 INTRODUCTION Plaintiffs National Trucking Financial Reclamation Services, LLC, Bruce Taylor, Edis Trucking, Jerry Floyd, Mike Campbell, Paul Otto, Townes Trucking, Inc., and R&R Transportation, Inc.(collectively, ―Plaintiffs‖) bring this putative class action against Pilot Flying J—the largest operator of travel centers in North America and the top retail seller of over-the- road diesel fuel in the United States—and various other corporate and individual defendants.
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