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Plaintiff's Notice of Motion, Motion for Final Approval of Class Action
Case 4:19-cv-01057-HSG Document 79 Filed 12/01/20 Page 1 of 26 Rachel E. Kaufman (CA Bar No. 259353) 1 [email protected] 2 Avi R. Kaufman (Pro hac vice) [email protected] 3 KAUFMAN P.A. 400 NW 26th Street 4 Miami, FL 33127 5 Telephone: (305) 469-5881 6 Attorneys for Plaintiff Izor and all others similarly situated (Additional counsel appearing on signature page) 7 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 ) Case No. 4:19-cv-01057-HSG 12 PAUL IZOR, individually and on behalf of all ) others similarly situated, ) PLAINTIFF’S NOTICE OF MOTION, 13 ) MOTION FOR FINAL APPROVAL OF Plaintiff, ) CLASS ACTION SETTLEMENT, 14 ) RESPONSE TO OBJECTION, AND 15 v. ) INCORPORATED MEMORANDUM OF ) LAW 16 ABACUS DATA SYSTEMS INC., a ) California corporation, ) Hearing Date: December 17, 2020 17 ) Hearing Time: 2:00 p.m. th 18 Defendant. ) Courtroom: 2 – 4 Floor ) Judge: Hon. Haywood S. Gilliam, Jr. 19 ) 20 21 TO THE HONORABLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF 22 RECORD: 23 PLEASE TAKE NOTICE that on December 17, 2020 at 2:00 p.m. or as soon thereafter 24 as this matter may be heard in Courtroom 2 – 4th Floor of the United States District Court for the 25 Northern District of California, Oakland Division, located at 1301 Clay Street, Oakland, CA 26 94612, before the Honorable Haywood S. Gilliam, Jr., Plaintiff Paul Izor will and hereby does 27 28 1 Motion for Final Approval of Class Settlement Case no. 4:19-cv-01057-HSG Case 4:19-cv-01057-HSG Document 79 Filed 12/01/20 Page 2 of 26 1 move the Court, by and through Class Counsel, for entry of an order granting final approval of 2 the class action settlement set forth in the Parties’ Settlement Agreement, certifying the Settlement 3 Class for settlement purposes, approving the Notice to the Settlement Class, and denying the one 4 objection to the settlement, which was filed by a non-class member.1 This Motion is based on and 5 supported by this Notice of Motion, the following Memorandum of Points and Authorities, the 6 Declaration of Avi R. -
Settlement Agreement Is Entered Into by Plaintiffs on Behalf of Themselves and 3 the Class Members, and Defendant Reckitt Benckiser, LLC
Case 3:17-cv-03529-VC Document 221-2 Filed 05/12/21 Page 2 of 141 1 BLOOD HURST & O’REARDON, LLP TIMOTHY G. BLOOD (149343) 2 THOMAS J. O’REARDON II (247952) 501 West Broadway, Suite 1490 3 San Diego, CA 92101 Tel: 619/338-1100 4 619/338-1101 (fax) [email protected] 5 [email protected] 6 Class Counsel 7 [Additional Counsel Appear on Signature Page] 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION 10 GORDON NOBORU YAMAGATA and Case No. 3:17-cv-03529-VC STAMATIS F. PELARDIS, individually and 11 on behalf of all others similarly situated, STIPULATION OF SETTLEMENT 12 Plaintiffs, LLP CLASS ACTION , 13 v. 14 RECKITT BENCKISER LLC, District Judge Vince Chhabria EARDON Courtroom 4, 17th Floor 15 Defendant. O’ R Complaint Filed: June 19, 2017 & 16 Trial Date: N/A URST 17 H 18 LOOD LOOD B 19 20 21 22 23 24 25 26 27 28 Case No. 3:17-cv-03529-VC 00177902 STIPULATION OF SETTLEMENT Case 3:17-cv-03529-VC Document 221-2 Filed 05/12/21 Page 3 of 141 1 TABLE OF EXHIBITS 2 Document Exhibit Number 3 Preliminary Approval Order ................................................................................................. 1 4 Final Approval Order ............................................................................................................ 2 5 Final Judgment ..................................................................................................................... 3 6 Class Notice Program ........................................................................................................... -
Petition for Writ of Certiorari in This Court
No. _________ ================================================================ In The Supreme Court of the United States --------------------------------- --------------------------------- DENNIS HOLLINGSWORTH, et al., Petitioners, v. KRISTIN M. PERRY, et al., Respondents. --------------------------------- --------------------------------- On Petition For A Writ Of Certiorari To The United States Court Of Appeals For The Ninth Circuit --------------------------------- --------------------------------- PETITION FOR A WRIT OF CERTIORARI --------------------------------- --------------------------------- ANDREW P. PUGNO CHARLES J. COOPER LAW OFFICES OF Counsel of Record ANDREW P. PUGNO DAVID H. THOMPSON 101 Parkshore Drive, Suite 100 HOWARD C. NIELSON, JR. Folsom, California 95630 PETER A. PATTERSON COOPER AND KIRK, PLLC DAVID AUSTIN R. NIMOCKS 1523 New Hampshire JAMES A. CAMPBELL Avenue, NW ALLIANCE DEFENDING FREEDOM Washington, D.C. 20036 801 G Street, NW, Suite 509 Tel: (202) 220-9600 Washington, D.C. 20001 Email: ccooper@ cooperkirk.com Counsel for Petitioners ================================================================ COCKLE LAW BRIEF PRINTING CO. (800) 225-6964 OR CALL COLLECT (402) 342-2831 i QUESTION PRESENTED Whether the Equal Protection Clause of the Fourteenth Amendment prohibits the State of Cali- fornia from defining marriage as the union of a man and a woman. ii PARTIES TO THE PROCEEDINGS BELOW Petitioners Dennis Hollingsworth, Gail J. Knight, Martin F. Gutierrez, Mark A. Jansson, and ProtectMarriage.com – Yes on 8, -
Exhibit 4 Case 4:19-Cv-06864-HSG Document 45-4 Filed 10/08/20 Page 2 of 129
Case 4:19-cv-06864-HSG Document 45-4 Filed 10/08/20 Page 1 of 129 Exhibit 4 Case 4:19-cv-06864-HSG Document 45-4 Filed 10/08/20 Page 2 of 129 AMENDED STIPULATION OF AGREEMENT AND SETTLEMENT AND RELEASE This Amended Stipulation of Agreement and Settlement and Release is entered into by and among the Named Plaintiffs (as defined below), for themselves and on behalf of the Settlement Class, and Defendants Chime Financial, Inc. (“Chime”), The Bancorp Inc. (“Bancorp”), and Galileo Financial Technologies, LLC (formerly known as Galileo Financial Technologies, Inc. and referred to herein as “Galileo”) (collectively, “Defendants”), subject to preliminary and final Court approval as required by Rule 23 of the Federal Rules of Civil Procedure. As provided herein, Defendants and the Named Plaintiffs hereby stipulate and agree that, in consideration of the promises and covenants set forth in this Agreement and upon entry by the Court of a final order and judgment, all claims of the Settlement Class against the Defendants in connection with the Service Disruption (defined below) as alleged in the action titled Richards, et al. v. Chime Financial, Inc., Case No. 4:19-cv-06864 (N.D. Cal.) shall be settled and compromised upon the terms and conditions contained herein. The Named Plaintiffs and Defendants are collectively referred to herein as the “Parties.” I. RECITALS A. Chime is the program manager for deposit accounts administered by Bancorp, for which Galileo acts as a processor (the “Accounts”). B. Some accountholders experienced an intermittent disruption in service for portions of the period of time between October 16, 2019 and October 19, 2019 (the “Service Disruption”). -
Administration of Barack Obama, 2014 Nominations Submitted to The
Administration of Barack Obama, 2014 Nominations Submitted to the Senate November 21, 2014 The following list does not include promotions of members of the Uniformed Services, nominations to the Service Academies, or nominations of Foreign Service Officers. Submitted January 6 Jill A. Pryor, of Georgia, to be U.S. Circuit Judge for the 11th Circuit, vice Stanley F. Birch, Jr., retired. Carolyn B. McHugh, of Utah, to be U.S. Circuit Judge for the 10th Circuit, vice Michael R. Murphy, retired. Michelle T. Friedland, of California, to be U.S. Circuit Judge for the Ninth Circuit, vice Raymond C. Fisher, retired. Nancy L. Moritz, of Kansas, to be U.S. Circuit Judge for the 10th Circuit, vice Deanell Reece Tacha, retired. John B. Owens, of California, to be U.S. Circuit Judge for the Ninth Circuit, vice Stephen S. Trott, retired. David Jeremiah Barron, of Massachusetts, to be U.S. Circuit Judge for the First Circuit, vice Michael Boudin, retired. Robin S. Rosenbaum, of Florida, to be U.S. Circuit Judge for the 11th Circuit, vice Rosemary Barkett, resigned. Julie E. Carnes, of Georgia, to be U.S. Circuit Judge for the 11th Circuit, vice James Larry Edmondson, retired. Gregg Jeffrey Costa, of Texas, to be U.S. Circuit Judge for the Fifth Circuit, vice Fortunato P. Benavides, retired. Rosemary Márquez, of Arizona, to be U.S. District Judge for the District of Arizona, vice Frank R. Zapata, retired. Pamela L. Reeves, of Tennessee, to be U.S. District Judge for the Eastern District of Tennessee, vice Thomas W. Phillips, retiring. -
Career News Archives Thursday, July 21, 2016 Archive of Recorded LOCATION: Littler Mendelson P.C
July 19, 2016 Littler Mendelson First Generation Professionals Mock Interview Program Littler Mendelson has organized an event designed to give your interview skills a final polish before the Bay Area Diversity Career Fair and the upcoming fall hiring season. Attorneys from Littler and other Bay Area firms, as well as in-house counsel, will share interview tips and then give you the chance to do the most important thing - practice! Learn ways to highlight your unique skills and experience while obtaining real-time feedback. Then get to know attorneys from the firms and companies with or for which you might soon be Alumni Directory working. Job Search Resources Space is limited, so please let us know if you're interested in taking part in this event by Thursday, July 14, 2016, by registering now. Symplicity DATE: Career News Archives Thursday, July 21, 2016 Archive of Recorded LOCATION: Littler Mendelson P.C. CSO Presentations 333 Bush Street, 34th Floor San Francisco, CA 94104 Walk-In Hours: AGENDA: Walk-in hours are suspended 6:00 - 6:10 p.m. Check In for the summer and will 6:10 - 6:30 p.m. Welcome and Interview Tips recommence in August. 6:30 - 7:00 p.m. Mock Interviews 7:00 - 8:00 p.m. Reception Please call 530.752.6574 to schedule an appointment and Questions? Please contact Juleantonette Lopez at [email protected] note whether you would like or 408.795.3432. to meet in person or over the phone. NW Minority Job Fair Deadline - July 22 Student registration for the NW Minority Job Fair is currently open and the deadline is approaching! For more information go here. -
Declaration of Cameron Azari on Implementation of Notice Plan
UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN YVONNE MART FOX, GRANT NESHEIM, Case No.: 18-CV-00327-JDP DANIELLE DUCKLEY, and SHELLEY KITSIS, individually and on behalf of all others similarly situated, Plaintiffs, v. IOWA HEALTH SYSTEM, doing business as UNITYPOINT HEALTH, an Iowa non-profit corporation, Defendant. DECLARATION OF CAMERON R. AZARI, ESQ. ON IMPLEMENTATION OF SETTLEMENT NOTICE PLAN AND ADEQUACY OF NOTICES I, Cameron R. Azari, declare as follows: 1. My name is Cameron R. Azari, Esq. The facts in this declaration are based on my personal knowledge, as well as information provided to me by my colleagues in the ordinary course of my business at Hilsoft and Epiq, and I believe them to be true and correct. 2. I am a nationally recognized expert in the field of legal notice and I have served as an expert in dozens of federal and state cases involving class action notice plans. 3. I am the Director of Legal Notice for Hilsoft Notifications (“Hilsoft”); a firm that specializes in designing, developing, analyzing and implementing large-scale legal notification plans. Hilsoft is a business unit of Epiq Class Action & Claims Solutions, Inc. (“Epiq”). 4. Hilsoft has been involved with some of the most complex and significant notice programs in recent history, examples of which are discussed below. With experience in more than 450 cases, including more than 40 multi-district litigations, Hilsoft has prepared notices which have appeared in 53 languages and been distributed in almost every country, territory, and DECLARATION OF CAMERON R. AZARI, ESQ. ON IMPLEMENTATION OF SETTLEMENT NOTICE PLAN AND ADEQUACY OF NOTICES dependency in the world. -
(“Hilsoft”) Is a Leading Provider of Legal Notice Services for Large-Scale Class Action and Bankruptcy Matters
Hilsoft Notifications (“Hilsoft”) is a leading provider of legal notice services for large-scale class action and bankruptcy matters. We specialize in providing quality, expert, and notice plan development – designing notice programs that satisfy due process requirements and withstand judicial scrutiny. Hilsoft is a business unit of Epiq Class Action & Claims Solutions, Inc. (“Epiq”). Hilsoft has been retained by defendants or plaintiffs for more than 500 cases, including more than 40 MDL cases, with notices appearing in more than 53 languages and in almost every country, territory and dependency in the world. For more than 25 years, Hilsoft’s notice plans have been approved and upheld by courts. Case examples include: Hilsoft designed and implemented monumental notice campaigns to notify current or former owners or lessees of certain BMW, Mazda, Subaru, Toyota, Honda, Nissan, and Ford vehicles as part of $1.49 billion in settlements regarding Takata airbags. The Notice Plans included individual mailed notice to more than 59.6 million potential class members and notice via consumer publications, U.S. Territory newspapers, radio, internet banners, mobile banners, and other behaviorally targeted digital media. Combined, the Notice Plans reached more than 95% of adults aged 18+ in the U.S. who owned or leased a subject vehicle with a frequency of 4.0 times each. In re: Takata Airbag Products Liability Litigation (OEMS – BMW, Mazda, Subaru, Toyota, Honda, Nissan and Ford), MDL No. 2599 (S.D. Fla.). For a landmark $6.05 billion settlement reached by Visa and MasterCard in 2012, Hilsoft implemented an intensive notice program, which included over 19.8 million direct mail notices to class members together with insertions in over 1,500 newspapers, consumer magazines, national business publications, trade and specialty publications, and language & ethnic targeted publications. -
Motion for Final Approval of Settlement.Pdf
1 Rob Bonta Attorney General of California 2 Renuka George Senior Assistant Attorney General 3 Emilio Varanini (SBN 163952) Supervising Deputy Attorney General 4 Malinda Lee (SBN 263806) Justin J. Lowe (SBN 223847) 5 Deputy Attorneys General 455 Golden Gate Avenue, Suite 11000 6 San Francisco, CA 94102-7004 Tel 415.510.3541 / Fax 415.703.5480 7 Email: [email protected] Attorneys for Plaintiff, People of the State of 8 California 9 Richard L. Grossman (SBN 112841) Philip L. Pillsbury Jr. (SBN 072261) 10 Pillsbury & Coleman, LLP 100 Green Street 11 San Francisco, CA 94111 Tel 415.433.8000 / Fax 415.433.4816 12 Email: [email protected] Lead Counsel for Plaintiff UFCW & Employers Benefit 13 Trust and the Class (Additional Counsel not listed) 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 FOR THE COUNTY OF SAN FRANCISCO 16 UFCW & Employers Benefit Trust, on behalf Case No: CGC 14-538451 17 of itself and all others similarly situated, Consolidated with Plaintiff, 18 Case No. CGC-18-565398 vs. PLAINTIFFS’ JOINT MOTION FOR FINAL 19 Sutter Health, et al., APPROVAL OF SETTLEMENT; NOTICE OF Defendants. MOTION; MEMORANDUM OF POINTS 20 AND AUTHORITIES IN SUPPORT 21 People of the State of California, ex rel. Date: July 19, 2021 22 Xavier Becerra, Plaintiff, Time: 9:15 a.m. 23 vs. Dept: 304 24 Sutter Health, Judge: Hon. Anne-Christine Massullo 25 Defendant Action Filed: April 7, 2014 26 UNREDACTED – MAY NOT BE 27 EXAMINED WITHOUT COURT ORDER CONTAINS MATERIALS FROM 28 CONDITIONALLY SEALED RECORD PLAINTIFFS’ JOINT MOTION FOR FINAL APPROVAL OF SETTLEMENT - Case No. -
Congressional Record—Senate S2984
S2984 CONGRESSIONAL RECORD — SENATE May 14, 2014 law enforcement officers across Ken- were forced to endure extremely long but tainting that promise of our com- tucky and the Nation. We are grateful wait times and, in some cases, they mitment to the next generation of our so many have come to town for Na- were denied those cancer screenings al- military servicemembers and veterans. tional Police Week. together. He said, as a result, up to The generation that is now preparing We recognize theirs as both an honor- ‘‘15,000 patients [veterans all] who to embark for places such as West able profession and a dangerous one. should have gotten colonoscopies ei- Point, Annapolis, and Colorado We recognize that what they do is vi- ther did not get them or were examined Springs—these young people should be tally necessary to maintain peace and only after long and needless delays.’’ given not just a promise but an iron- order in a civil society. Dr. Krugman believes that some of clad commitment that after serving f these veterans actually died as a result our Nation with honor and courage of the lack of cancer screening and ad- they will get the support they have RESERVATION OF LEADER TIME dressing their symptoms. earned and they deserve. The ACTING PRESIDENT pro tem- He also told the Examiner that ‘‘an Anything less is just not acceptable. pore. Under the previous order, the office secretary deleted about 1,800 or- I yield the floor. leadership time is reserved. ders for medical tests or other services The ACTING PRESIDENT pro tem- pore. -
Motion for Final Approval of Class Action Settlement
UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY : Scott D. Sager, Edward Young, Renada Hall, : Michael Marcotte, Sharon Scott, Jack : Whittington, Carmelita Nunez, on behalf of : themselves and all others similarly situated, : : Plaintiffs, : Civil Action No. 2:18-cv-13556 (ES) (SCM) vs. : : Volkswagen Group of America, Inc., and Audi : of America, Inc., : : Defendants. : : : MOTION FOR FINAL APPROVAL OF THE PARTIES’ CLASS ACTION SETTLEMENT Plaintiffs, Scott D. Sager, Edward Young, Renada Hall, Michael Marcotte, Sharon Scott, Jack Whittington, and Carmelita Nunez (“Plaintiffs”) respectfully move for entry of an Order granting final approval of the Settlement Agreement between Plaintiffs and Defendants Volkswagen Group of America, Inc. and Audi of America, Inc. (“Defendants” or “VWGoA”)1 In support, Plaintiffs submit (i) Plaintiffs’ Memorandum of Law in Support of Motion for Final Approval of Class Action Settlement; (ii) the May 27, 2021 Declaration of Cameron R. Azari, Senior Vice President at Epiq, the class action administrator; and (iii) the May 31, 2021, Declaration from Stephen Taylor. 1 Audi of America, Inc. is not a separate entity. It is an operating unit of Volkswagen Group of America, Inc. 1 Plaintiffs respectfully request that the Court approve the settlement as fair, reasonable and adequate and enter the Parties’ Proposed Final Approval Order.2 Dated: May 31, 2021 Respectfully submitted, /s/ Sergei Lemberg Sergei Lemberg (phv) /s/ Stephen Taylor Stephen Taylor (phv) /s/ Sofia Balile Sofia Balile LEMBERG LAW, LLC 43 Danbury Road Wilton, CT 06897 Telephone: (203) 653-2250 Facsimile: (203) 653-3424 Attorneys for Plaintiffs 2 The Parties’ Proposed Final Approval Order will be lodged with the Court ahead of the Final Fairness Hearing. -
* This Document Is a Case Summary Compilation of Select Employee Retirement Income Security Act of 1974 (“ERISA”) Decisions
* This document is a case summary compilation of select Employee Retirement Income Security Act of 1974 (“ERISA”) decisions as they were reported on Westlaw between January 1, 2016 and December 31, 2016. Nothing in this document constitutes legal advice. Case summaries prepared by Michelle L. Roberts, Partner, Roberts Bartolic LLP, 1050 Marina Village Parkway, Suite 105, Alameda, CA 94501. © Roberts Bartolic LLP I. Attorneys’ Fees .................................................................................................................... 9 A. First Circuit ........................................................................................................................................ 9 B. Second Circuit ................................................................................................................................... 9 C. Third Circuit ..................................................................................................................................... 12 D. Fourth Circuit .................................................................................................................................. 12 E. Fifth Circuit ...................................................................................................................................... 13 F. Sixth Circuit ..................................................................................................................................... 14 G. Seventh Circuit ...............................................................................................................................