IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION 

GERARDO ARANDA, GRANT 

BIRCHMEIER, STEPHEN PARKES, and 

REGINA STONE, on behalf of themselves and 

a class of others similarly situated,

Plaintiffs, 

v. 

CARIBBEAN CRUISE LINE, INC., 

ECONOMIC STRATEGY GROUP, 

ECONOMIC STRATEGY GROUP, INC., 

ECONOMIC STRATEGY, LLC, THE 

BERKLEY GROUP, INC., and VACATION 

OWNERSHIP MARKETING TOURS, INC., 

Defendants.

Case No. 1:12-cv-04069 

Honorable Matthew F. Kennelly

PLAINTIFFS’ CORRECTED MOTION FOR LEAVE INSTANTER 

TO FILE EXCESS LENGTH MOTION FOR PRELIMINARY APPROVAL 

Pursuant to Local Rule 7.1, Plaintiffs Gerardo Aranda, Grant Birchmeier, Stephen Parkes, 

and Regina Stone (“Plaintiffs”) respectfully request permission to file instanter a nineteen (19) 

page motion for preliminary approval of the class action settlement in this case. In support of this 

motion, Plaintiffs state as follows: 

1) After more than four years of litigation, during which Plaintiffs, among other

things, secured certification of two classes, won partial summary judgment, and defeated 

Defendants’ motions for summary judgment, and just days before a trial was scheduled to begin, 

the Parties in this case reached a class-wide settlement. 

2) Pursuant to Federal Rule of Civil Procedure 23, Plaintiffs are seeking the Court’s

approval of that settlement. The first step in that process is filing a motion for preliminary 

approval, in which Plaintiffs explain the terms of the settlement in detail, and also explain the 

proposed plan to notify class members of the settlement. 

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3) To ensure that they presented the Court with all of the factual and legal basis for

preliminarily approving the settlement and approving the proposed notice plan, Plaintiffs 

required slightly more than the fifteen pages provided for in Local Rule 7.1

4) In total, Plaintiffs’ motion is nineteen (19) pages.

WHEREFORE, Plaintiffs respectfully requests leave instanter to file their 19-page 

motion for preliminary approval.

Dated: September 27, 2016 Respectfully submitted by: 

/s/ Scott R. Rauscher

Jay Edelson 

EDELSON PC

350 North LaSalle Street, 13th Floor 

Chicago, Illinois 60654 

Telephone: (312) 589-6370 

Email: jedelson@edelson.com 

Rafey S. Balabanian 

Eve-Lynn J. Rapp 

EDELSON PC

123 Townsend Street, Suite 100 

San Francisco, California 94107 

Telephone: (415) 212-9300 

Email: rbalabanian@edelson.com 

erapp@edelson.com 

Scott R. Rauscher 

Michael I. Kanovitz 

Jonathan I. Loevy 

LOEVY & LOEVY

311 N. Aberdeen St., 3d Floor

Chicago, Illinois 60607 

Telephone: (312) 243-5900 

Email: scott@loevy.com 

jon@loevy.com 

mike@loevy.com 

Class Counsel 

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CERTIFICATE OF SERVICE 

I, Eve-Lynn J. Rapp, certify that on September 27, 2016, I caused the foregoing 

Plaintiffs’ Motion for Leave Instanter to File Excess Length Motion for Preliminary 

Approval, to be served by CM/ECF electronic filing on all counsel of record. 

/s/ Scott R. Rauscher

Case: 1:12-cv-04069 Document #: 500 Filed: 09/27/16 Page 3 of 3 PageID #:12037