Of 23 Case No: 19-L-0846 CIRCUIT COURT for the 20TH JUDICIAL CIRCUIT COUNTY of ST. CLAIR, STATE of ILLINOIS LISA MOORE
Electronically Filed Kahalah A. Clay Circuit Clerk CARMEN GLENN 19L0846 St. Clair County CIRCUIT COURT FOR THE 20TH JUDICIAL CIRCUIT 6/22/2020 10:42 AM COUNTY OF ST. CLAIR, STATE OF ILLINOIS 9555049 LISA MOORE, individually and on behalf of ) all others similarly situated, ) ) Plaintiff, ) v. ) No. 19-L-0846 ) KIMBERLY-CLARK WORLDWIDE, INC., ) ) Defendant. ) MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND MEMORANDUM IN SUPPORT THEREOF Plaintiff Lisa Moore (“Plaintiff”), by and through Class Counsel,1 respectfully submits this memorandum in support of Plaintiff’s Motion for Final Approval of Class Action Settlement. The Settlement Agreement (hereafter, “Settlement”) and its exhibits are attached as Exhibit 1 to the concurrently filed Declaration of Scott A. Bursor In Support Of Plaintiff’s Application For Attorneys’ Fees, Costs, And Class Service Awards (“Bursor Decl.”). On April 21, 2020, this Court granted preliminary approval to the parties’ Settlement Agreement and ordered that the Settlement Administrator execute the approved Notice Plan. See Order Granting Preliminarily Approval of Class Action Settlement. The tremendous response from Class Members confirms that the Settlement is fair and reasonable and provides outstanding relief to the Class. Although the claims deadline is not until August 18, 2020, the Claims Administrator estimates that upon receipt of 228,311 Claims, the entire $7,000,000 Benefit Fund will be exhausted. See Exhibit MFA1, the June 22, 2020 Decl. of Jeanne C. 1 All capitalized terms not otherwise defined herein shall have the same definitions as set out in the Settlement Agreement. Page 1 of 23 Case No: 19-L-0846 Finegan (“Finegan Decl.”) ¶ 31.
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