THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JASEN WRIGHT, Individually, and on Behalf

of All Others Similarly Situated,

Plaintiffs,

v.

PIRTANO CONSTRUCTION COMPANY,

INC., JACK HORN, COMCAST

CORPORATION, and COMCAST CABLE

COMMUNICATIONS MANAGEMENT, LLC

Defendants.

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Case no. 12-cv-04949

Judge Virginia M. Kendall

Magistrate Judge Daniel G. Martin

JOINT MOTION FOR FINAL APPROVAL OF CLASS SETTLEMENT

Named Plaintiff JASEN WRIGHT (“Named Plaintiff” or “Class Representative”), on

behalf of himself and all members of the Settlement Class1(“Class Members”) (and all Plaintiffs

hereinafter collectively referred to as “Plaintiffs”) on one hand, and Defendants PIRTANO

CONSTRUCTION COMPANY, INC. and JACK HORN (collectively, “Pirtano Defendants”)

and Defendants COMCAST CORPORATION and COMCAST CABLE COMMUNICATIONS

MANAGEMENT, LLC (collectively, “Comcast”) (and all Defendants hereinafter collectively

referred to as “Defendants”) on the other hand (collectively, the “Parties”), by their respective

attorneys, respectfully move this Court for entry of an Order granting final approval of the

Parties’ settlement of Plaintiffs’ claims that Defendants violated the Illinois Minimum Wage

Law, 820 ILCS § 105/1, et seq. (“IMWL”), the Illinois Wage Payment and Collection Act, 820

ILCS § 115/1, et seq. (“IWPCA”) and the Illinois Employee Classification Act, 820 ILCS §

1 Where applicable, capitalized terms not otherwise defined in this Motion are as they are defined in the

Class Action Settlement Agreement submitted with Plaintiffs’ Unopposed Motion for Preliminary

Approval of Class Settlement.

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185/1, et seq. (“IECA”).2In support of their motion, the Parties submit a supporting

Memorandum of Law and exhibits attached thereto, and state as follows:

1. On December 12, 2013, the Court certified the Class for settlement purposes only

and granted preliminary approval to the Parties’ $442,500.00 Settlement of Plaintiffs’ claims.

(Dkt. No. 68).

2. Final approval is appropriate where the court determines that a settlement is fair,

adequate, and reasonable. Synfuel Techs., Inc. v. DHL Express (USA), Inc., 463 F.3d 646, 652

(7th Cir. 2005).

3. The Settlement in this case has been achieved in good faith and through arm'slength negotiations and is not the product of fraud or collusion.

4. The Settlement offers substantial monetary relief to the Settlement Class.

5. The Settlement is overwhelmingly supported by Class Members. The fact that

only one (1) of the Class Members timely requested exclusion from the Settlement and not a

single Class Member objected to the Settlement shows strong support for the Settlement.

6. The record indicates that all criteria under Federal Rule of Civil Procedure 23 are

met for purposes of settlement for the Settlement Class, and the Parties have provided the Class

with adequate notice of the terms and conditions of the Settlement in a manner intended to

maximize the due process rights of the Class Members.

7. Additionally, experienced Counsel for the Parties have extensively analyzed the

claims and issues herein, and have certified that the Settlement is fair, reasonable, and adequate,

and in the best interest of the Class. Thus, the Court should: (1) grant final approval of the

Settlement Agreement; (2) find the Settlement fair, reasonable, adequate, and in the best interests

2 The Named Plaintiff also asserted individual claims under the Fair Labor Standards Act, 29 U.S.C. §

201, et seq. (“FLSA”).

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of the Class Members; (3) approve Class Counsel’s application for an award of attorneys’ fees

and costs; (4) approve the Named Plaintiff’s application for a Service Payment; (5) approve the

payment of reasonable Settlement Administration Costs; and (6) enter the Plaintiffs’ proposed

final approval order dismissing the Action and releasing and barring the claims released by Class

Members under the terms of the Settlement Agreement.

WHEREFORE, the Parties respectfully request that the Court enter the proposed Order of

Final Approval of the Settlement, attached as Exhibit 1.

Dated: March 28, 2014

JASEN WRIGHT,

By: /s/ Ryan F. Stephan

One of His Attorneys

COMCAST CORPORATION and

COMCAST CABLE COMMUNICATIONS

MANAGEMENT, LLC,

By: /s/ Sari Alamuddin

One of Their Attorneys

James B. Zouras

Ryan F. Stephan

STEPHAN ZOURAS, LLP

205 N. Michigan Avenue, Suite 2560

Chicago, Illinois 60601

Tel: 312.233.1550

Fax: 312.233.1560

jzouras@stephanzouras.com

rstephan@stephanzouras.com

Sari M. Alamuddin

MORGAN, LEWIS & BOCKIUS LLP

77 West Wacker Dr.

Fifth Floor

Chicago, IL 60601

Tel. 312.324.1000

Fax 312.324.1001

salamuddin@morganlewis.com

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PIRTANO CONSTRUCTION COMPANY,

INC. and JACK HORN,

By: /s/ Jonathan Hoag

One of Their Attorneys

Jonathan Hoag

SMITHAMUNDSEN LLC

3815 E. Main Street, Suite A-1

St. Charles, Illinois 60174

Tel: 630.587.7911

Fax: 630.587.7960

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