Class Notices

• Summary Postcard Notice
• Notice of (i) Pendency of Class Action and Proposed Settlement; (ii) Final Approval Hearing; and (iii) Motion for Attorneys’ Fees and Reimbursement of Litigation Expenses
• Sample Proof of Claim and Release Form
• Sample Validation Letter

Class Action Complaint

• First Amended Consolidated Class Action Complaint
• Answer to the First Amended Consolidated Consolidated Class Action Complaint

Settlement Documents

• Notice of Plaintiff’s Unopposed Motion for Preliminary Approval of Proposed Class Action Settlement
• Memorandum of Law in Support of Plaintiff’s Unopposed Motion Unopposed Motion for Preliminary Approval of Proposed Class Action Settlement
  • Ciresi Conlin Resume
  • McTigue Law Resume
  • Analytics Overview
  • Analytics Resume
• Stipulation and Agreement of Settlement
  • Proposed Order Preliminarily Approving Settlement and Providing for Notice
  • Proposed Notice of (i) Pendency of Class Action and Proposed Settlement; (ii) Final Approval Hearing; and (iii) Motion for Attorneys’ Fees and Reimbursement of Litigation Expenses
  • Proposed Validation Letter
  • Proposed Proof of Claim and Release Form
  • Proposed Publication Notice
  • Proposed Postcard Notice
  • Proposed Order and Final Judgement
  • Proposed Order Preliminarily Approving Settlement and Providing for Notice

Orders

• • Order Preliminarily Approving Settlement and Providing for Notice
  • Order and Final Judgment

Final Approval

• • Unopposed Motion for Final Approval of Class Action Settlement and Plan of Allocation
  • Named Plaintiffs’ Memorandum of Law in Support of Unopposed Motion for Final Approval of Class Action Settlement and Plan of Allocation
  • Declaration of Richard W. Simmons
  • Proposed Order and Final Judgment
  • Notice of Motion for Attorneys’ Fees, Reimbursement of Litigation Expenses, and Service Awards
  • Memorandum of Law in Support of Motion for Attorneys’ Fees, Reimbursement of Litigation Expenses, and Service Awards
  • Declaration of Heather M. McElroy in Support of (I) Unopposed Motion for Final Approval of Class Action Settlement and Plan of Allocation and (II) Motion for Attorneys’ Fees, Reimbursement of Litigation Expenses, and Service Awards
  • Declaration of J. Brian McTigue in Support of Motion for Attorneys’ Fees and Reimbursement of Litigation Expenses
  • Declaration of Jonathan G. Axelrod in Support of Motion for Attorneys’ Fees and Reimbursement of Litigation Expenses Filed on Behalf of Beins, Axelrod, P.C.
  • Declaration of Sidney H. Kalban, Esq.
  • Declaration of Marc H. Rifkind in Support of Motion for Attorneys’ Fees and Reimbursement of Litigation Expenses