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.