IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

VANESSA CHAVEZ, )

KEITH DISMUKES, and )

LATASHA TURNER, )

individually and on behalf of a ) Case No. 12-cv-5563

class of persons similarly situated, )

)

Plaintiffs, ) Judge Joan B. Gottschall

)

v. )

) Magistrate Judge Susan E. Cox

HAT WORLD, INC., a Minnesota )

corporation, )

)

Defendant. )

PLAINTIFFS’ MOTION FOR FINAL APPROVAL

OF THE PARTIES’ JOINT STIPULATION OF SETTLEMENT AND RELEASE

Plaintiffs, Vanessa Chavez, Keith Dismukes, and Latasha Turner, individually and on 

behalf of a class of persons similarly situated, by their attorneys, respectfully move for the entry 

of an Order granting final approval of the Parties’ Settlement Agreement and Release (the 

“Settlement Agreement”). In support of their motion, Plaintiffs submit a supporting 

Memorandum of Law, the Declarations of Class Counsel, and the Declaration of Kristin Dahl as 

authorized agent of the Claims Administrator, and state as follows:

1. On May 9, 2014, this Court granted preliminary approval of the settlement of the 

Plaintiffs’ and the Class Members’ claims (the “Settlement”). (Dkt. No. 128).

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). 

Case: 1:12-cv-05563 Document #: 131 Filed: 08/22/14 Page 1 of 3 PageID #:1314
3. The Settlement in this case was achieved in good faith and through arms-length 

negotiations, and is not the product of fraud or collusion.

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

5. The Settlement is overwhelmingly supported by class members. None of the 

1,559 Class Members submitted a request for exclusion or objected to the Settlement. These 

facts show strong support for the Settlement.

6. Plaintiff has provided the Class Members with adequate notice of the terms and 

conditions of the Settlement in a manner intended to maximize their due process rights.

7. Additionally, experienced Class Counsel have extensively analyzed the claims 

and issues herein, and certify that the Settlement is fair, reasonable, and adequate, and in the best 

interest of the Class Members. Thus, the Court should grant final approval of the Settlement, 

find the Settlement fair, reasonable, adequate, and in the best interests of the Class Members, 

approve Class Counsel’s request for an award of attorneys’ fees and costs, approve the Service

Payments to the Class Representatives, and enter the proposed final approval order dismissing 

this action.

WHEREFORE, Plaintiffs respectfully request that this Honorable Court enter the 

proposed Final Approval and Dismissal Order, attached as Exhibit 1 to Plaintiffs’ Memorandum 

of Law.

Respectfully submitted,

VANESSA CHAVEZ, KEITH DISMUKES, and 

LATASHA TURNER, individually and on behalf 

of a certified class of persons similarly situated,

/s/ James X. Bormes

One of Plaintiffs’ Attorneys

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Case: 1:12-cv-05563 Document #: 131 Filed: 08/22/14 Page 2 of 3 PageID #:1315
James X. Bormes Thomas M. Ryan

Catherine P. Sons Law Office of Thomas M. Ryan, P.C.

Law Office of James X. Bormes, P.C. 35 E. Wacker Drive 

8 South Michigan Avenue Suite 650

Suite 2600 Chicago, Illinois 60601 

Chicago, Illinois 60603 (312) 726-3400

(312) 201-0575

Jeffrey Grant Brown

Jeffrey Grant Brown, P.C.

221 N. LaSalle Street

Suite 1414

Chicago, Illinois 60601

(312) 789-9700

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Case: 1:12-cv-05563 Document #: 131 Filed: 08/22/14 Page 3 of 3 PageID #:1316