IN THE UNITED STATED DISTRICT COURT 

FOR THE EASTERN DISTRICT OF MICHIGAN 

Southern Division 

BLEACHTECH LLC, individually and on 

behalf of all others similarly situated, 

Plaintiff, 

v. 

UNITED PARCEL SERVICE CO., 

Defendant. 

Case No. 2:14-cv-12719 

Hon. Denise Page Hood

_______________________________________/ 

Andrew J. McGuinness (P42074) 

ANDREW J. MCGUINNESS, ESQ. 

122 S Main St, Ste 118 

P.O. Box 7711 

Ann Arbor, MI 48107 

Tel. (734) 274-9374 

drewmcg@topclasslaw.com 

Daniel R. Karon (admitted) 

KARON LLC 

700 W St Clair Ave, Ste 200 

Cleveland, OH 44113 

Phone: (216) 622-1851 

dkaron@karonllc.com 

Sanford P. Dumain (admitted) 

MILBERG PHILLIPS GROSSMAN LLP 

100 Garden City Plaza, Suite 500 

Garden City, New York 11530 

Phone: (212) 594-5300 

sdumain@milberg.com 

Counsel for Plaintiffs and the Class 

Gregory B. Koltun (admitted) 

Erin P Lupfer 

MORRISON & FOERSTER LLP 

707 Wilshire Blvd 

Los Angeles, CA 90017-3543 

Phone: (213) 892-5200 

gkoltun@mofo.com 

elupfer@mofo.com 

Caitlin Sinclaire Blythe (admitted) 

MORRISON & FOERSTER LLP 

425 Market St 

San Francisco, CA 94105-2482 

Phone: (415) 268-7000 

cblythe@mofo.com 

Sonal Hope Mithani (P51984) 

MILLER, CANFIELD, PADDOCK & STONE, PLC 

150 W Jefferson, Ste 2500 

Detroit, MI 48226 

Phone: (313) 496-7669 

mithani@millercanfield.com 

Counsel for Defendant 

_____________________________________________________________________________/ 

STIPULATED ORDER STAYING DISTRIBUTION PLAN 

WHEREAS on July 20, 2022, this Court entered its Final Approval Order 

approving the parties’ Amended Class Action Settlement Agreement (ECF No. 

155), which documents contain detailed plans for distribution of the Net Settlement 

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Fund to class members (“Distribution Plan”); and 

WHEREAS counsel has advised the Court that, based on recently obtained 

distribution data, Class Counsel believes it is in the best interest of the Class to 

modify the original Distribution Plan, as set forth in the Final Approval Order and 

the Amended Class Action Settlement Agreement; and 

WHEREAS, the Court is advised that upcoming distribution deadlines may 

result in significant foreseeable waste of Net Settlement Proceeds, and 

WHEREAS, Class Counsel anticipates that they will shortly file a Motion to 

Modify Distribution Plan, which they expect will be unopposed by Defendant, and 

the Court being fully advised in the premises; 

NOW, THEREFORE, it is hereby ORDERED that: 

 The Distribution Plan and schedule reflected in the Final Approval 

Order and Amended Class Action Settlement Agreement is hereby 

STAYED, pending further order of this Court; 

 The Settlement Administrator, Epiq Class Action & Claims 

Solutions, Inc., shall suspend any and all distribution of settlement 

proceeds to class members via checks (bank drafts) that were to be 

mailed to class members under the Distribution Plan, pending further 

order of this Court; 

 Plaintiff shall file a Motion to Amend Distribution Plan by October 

14, 2022, and indicate in said motion whether or not it is opposed; 

 Promptly after its filing, the Settlement Administrator shall post a 

copy of any Motion to Amend Distribution Plan to the Settlement 

Website, and post any additional notifications to the Settlement 

Website it deems appropriate in light of this Agreed Order; and 

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 Class Counsel shall continue to keep the Court generally advised of 

the status of significant developments in the implementation of the 

settlement, including the eventual completion thereof pursuant to any 

modified distribution plan. 

SO ORDERED. 

Dated: October 11, 2022 s/Denise Page Hood 

Denise Page Hood 

United States District Judge 

STIPULATED AND AGREED: 

/s/ Andrew J. McGuinness______ /s/_Gregory B. Koltun (by AJM, w/permission)

Andrew J. McGuinness (P42074) 

Counsel for Plaintiffs 

Gregory B. Koltun (admitted) 

Counsel for Defendant 

 

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