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Plaintiffs' Amended Unopposed Motion for Preliminary Case 1:16-cv-01122-VEC Document 134 Filed 07/21/20 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MICHELLE MARINO, DEBORAH CASE NO.: ESPARZA, MONICA RAEL, and CERA 1:16-cv-01122-VEC (OTW) (Lead) HINKEY, on behalf of themselves and all others similarly situated, Consolidated Member Case Nos.: 1:16-cv-03773-VEC (OTW) Plaintiffs, 1:16-cv-03677-VEC (OTW) 1:16-cv-05320-VEC (OTW) v. COACH, INC., Defendant. PLAINTIFFS’ AMENDED UNOPPOSED MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, PRELIMINARY CERTIFICATION OF SETTLEMENT CLASS, AND APPROVAL OF NOTICE PLAN Plaintiffs Michelle Marino, Deborah Esparza, Monica Rael, and Cera Hinkey (“Plaintiffs”), individually and on behalf of all others similarly situated, respectfully move the Court for an Order preliminarily approving the proposed class action settlement (“Settlement”), approving the Notice Plan, 1 and scheduling the final approval hearing as set forth in the Settlement Agreement attached as Exhibit 1 to the Declaration of Charles D. Moore (“Moore Declaration”). Specifically, Plaintiffs ask that the Court enter the proposed Order, thereby 1. Certifying the Settlement Class and appointing Plaintiffs as the class representatives and their counsel as Class Counsel; 2. Preliminarily approving the Settlement Agreement; 3. Approving the Notice Plan; 4. Preliminarily certifying the Settlement Class for purposes of settlement only; 1 Unless otherwise indicated, all capitalized terms herein shall have the same meaning as those defined in the Settlement Agreement (“Settlement” or “Agreement”). Case 1:16-cv-01122-VEC Document 134 Filed 07/21/20 Page 2 of 3 5. Appointing Angeion Group as Settlement Administrator and directing it to commence the Notice Plan; and 6. Scheduling a Fairness Hearing to consider final approval of the Settlement. In support of this Unopposed Motion, Plaintiffs rely on the attached Memorandum of Law, as well as the Declarations of Charles D. Moore, Steven Weisbrot, Esq. of Angeion Group, LLC, Bradley Breuer, and their supporting exhibits, and all documents filed therewith. Dated: July 21, 2020 Respectfully submitted, Andrea Gold Charles D. Moore TYCKO & ZAVAREEI LLP Christopher J. Moreland 1828 L. Street, N.W., Suite 1000 HALUNEN LAW Washington, D.C. 20036 1650 IDS Center Tel: 202.973.0900 80 South 8th Street [email protected] Minneapolis, Minnesota 55402 Tel: 612.605.4098 Charles J. LaDuca, Esquire [email protected] Beatrice Yakubu, Esq. [email protected] CUNEO GILBERT & LADUCA, LLP 4725 Wisconsin Avenue, Suite 200 Jeffrey M. Ostrow Washington, DC 20016 KOPELOWITZ OSTROW FERGUSON Telephone: 202 789 3960 WEISELBERG GILBERT [email protected] One West Las Olas Boulevard., Suite 500 [email protected] Fort Lauderdale, FL 33301 Tel: 954.525.4100 Erica Mirabella [email protected] MIRABELLA LAW, LLC [email protected] 132 Boylston Street, 5th Floor Boston, MA 02116 Tel: 855.505.5342 Attorneys for Plaintiff Marino and the Proposed Class 2 Case 1:16-cv-01122-VEC Document 134 Filed 07/21/20 Page 3 of 3 /s/David M. Cialkowski David M. Cialkowski June P. Hoidal ZIMMERMAN REED LLP 1100 IDS Center 80 South 8th Street Minneapolis, MN 55402 Tel: 612.341.0400 [email protected] [email protected] Attorneys for Plaintiff Esparza and the Proposed Class Todd D. Carpenter CARLSON LYNCH SWEET KILPELA & CARPENTER, LLP 402 West Broadway, 29th Floor San Diego, CA 92101 Tel: 619.347.3517 [email protected] Attorneys for Plaintiff Rael and the Proposed Class Richard D. Lambert STONEBARGER LAW 75 Iron Point Circle, Ste. 145 Folsom, CA 95630 Tel: 916.235.7140 [email protected] Attorneys for Plaintiff Hinkey and the Proposed Class 3 Case 1:16-cv-01122-VEC Document 134-1 Filed 07/21/20 Page 1 of 44 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MICHELLE MARINO, DEBORAH CASE NO.: ESPARZA, MONICA RAEL, and CERA 1:16-cv-01122-VEC (OTW) (Lead) HINKEY, on behalf of themselves and all others similarly situated, Consolidated Member Case Nos.: 1:16-cv-03773-VEC (OTW) Plaintiffs, 1:16-cv-03677-VEC (OTW) 1:16-cv-05320-VEC (OTW) v. COACH, INC., Defendant. PLAINTIFFS’ MEMORANDUM OF LAW IN SUPPORT OF AMENDED UNOPPOSED MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, PRELIMINARY CERTIFICATION OF SETTLEMENT CLASS, AND APPROVAL OF NOTICE PLAN Case 1:16-cv-01122-VEC Document 134-1 Filed 07/21/20 Page 2 of 44 TABLE OF CONTENTS TABLE OF AUTHORITIES .......................................................................................................................................... iv I. INTRODUCTION ............................................................................................................................................................ 1 II. HISTORY OF LITIGATION .................................................................................................................................... 2 III. CLASS COUNSEL’S INVESTIGATION ........................................................................................................ 5 IV. THE TERMS OF THE SETTLEMENT ............................................................................................................. 5 A. The Settlement Class .............................................................................................................................................. 5 B. Relief for the Benefit of the Settlement Class ............................................................................................ 6 1. Monetary Relief ................................................................................................................................................. 6 2. Injunctive Relief ................................................................................................................................................ 7 C. Incentive Awards and Attorneys’ Fees and Expenses ............................................................................ 7 D. Settlement Notice .................................................................................................................................................... 8 E. Processing of Claims and Method of Distribution ................................................................................ 13 F. Proposed Schedule ................................................................................................................................................ 14 V. ARGUMENT ................................................................................................................................................................. 14 A. The Court Should Preliminarily Approve the Settlement Agreement ........................................ 10 B. Legal Standard ........................................................................................................................................................ 15 C. The Proposed Settlement Meets the Requirements of Rule 23(e)(2) ............................................ 16 1. The Class Representatives and Class Counsel Have Adequately Represented the Class ............................................................................................................................................................................... 16 2. The Settlement was Negotiated at Arm’s Length ........................................................................... 18 3. The Monetary and Injunctive Relief Provided for the Settlement Class is Adequate .. 18 a. The costs, risks, and delay of trial and appeal weigh in favor of preliminary approval ............................................................................................................................................................ 20 b. The effectiveness of any proposed method of distributing relief to the Settlement Class and processing class-member claims weighs in favor of preliminary approval .................................................................................................................................................... 21 c. The terms of the proposed award of attorney’s fees weigh in favor of preliminary approval .................................................................................................................................................... 22 d. Agreements required to be identified under Rule 23(e)(3) ................................................. 23 4. The Settlement Treats Class Members Equitably Relative to Each Other ......................... 23 D. The Proposed Settlement Is Procedurally and Substantively Fair Under Second Circuit Jurisprudence ......................................................................................................................................................... 24 1. Procedural Fairness ....................................................................................................................................... 24 ii Case 1:16-cv-01122-VEC Document 134-1 Filed 07/21/20 Page 3 of 44 2. Substantive Fairness ..................................................................................................................................... 25 a. The complexity, expense, and likely duration of litigation ................................................ 26 b. The reaction of the class to the settlement ................................................................................. 26 c. The stage of the proceedings and the amount of discovery completed ........................ 26 d. The risks of establishing liability and damages
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