889936_1 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

LAWRENCE E. JAFFE PENSION PLAN, On 

Behalf of Itself and All Others Similarly 

Situated, 

Plaintiff, 

vs. 

HOUSEHOLD INTERNATIONAL, INC., et 

al., 

Defendants. 

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Lead Case No. 02-C-5893 

(Consolidated) 

CLASS ACTION 

Judge Ronald A. Guzman 

MOTION FOR AN ORDER APPROVING THE FORM AND MANNER OF NOTICE 

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Pursuant to this Court’s October 23, 2013 Order Setting Schedule for (1) Lead Counsel’s 

Application for an Award of Attorneys’ Fees and Non-Taxable Costs and (2) Lead Plaintiffs’ 

Application for an Award of Expenses, Lead Plaintiffs submit the Proposed Notice, attached as 

Exhibit A for the Court’s approval. 

As plaintiffs detailed in their submission on October 21, 2013, Rule 23(h)(1) requires that 

“[n]otice of the motion [for attorney’s fees] must be served on all parties and, for motions by class 

counsel, directed to class members in a reasonable manner.” Lead Counsel suggests that notice be 

sent by mail or e-mail to all of the class members whose claims have been allowed by the Court, i.e., 

the 10,902 class members identified in Exhibit A of the Judgment, which was entered on October 17, 

2013, who provided a mail or e-mail address in connection with their claim. The claims 

administrator has addresses for the affected class members who filed directly, as well as for many 

class members who filed through a third party, and will be in a position to send the Notice to these 

class members directly. As to class members who filed through custodian banks or third-party filing 

services (and did not provide addresses), Lead Counsel suggests that the claims administrator 

provide notice to these class members through their filer by mail or e-mail, unless the filer, within 10 

days of the Notice Date, provides the claims administrator with contact information and requests that 

the claims administrator mail the notice directly to their clients. 

Since Lead Counsel will only seek an award of fees and expenses at this time from the 

common fund obtained for the class members identified in Exhibit A to the Judgment, these class 

members are the only persons entitled to notice and with standing to object to this fee and expense 

application. Silverman v. Motorola Solutions, Inc., No. 12-2339, 2013 U.S. App. LEXIS 16878, at 

*2-*3 (7th Cir. Aug. 14, 2013) (objector “did not file a claim to his share of the recovery. He thus 

lacks any interest in the amount of fees, since he would not receive a penny from the fund even if 

counsel’s take should be reduced to zero. . . . We dismiss his appeal on the ground that he lacks any

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interest in the outcome.”). Because of the high likelihood that all affected class members will 

receive the mailed or emailed notice as described above, notice by publication is unnecessary. 

The Proposed Notice will be sent to the affected class members within 15 days of the entry of 

an Order Approving the Form and Manner of Notice. The Court approved the following schedule on 

October 23, 2013: 

Notice mailed or e-mailed to Class Members 

identified on Exhibit A to the Judgment. 

15 calendar days after the Court enters an order 

approving the Notice (hereinafter, “the Notice 

Date”). 

Deadline for filing motion for an award of 

attorney’s fees and non-taxable costs and Lead 

Plaintiffs’ application for reimbursement of 

expenses (“the Fee and Expense Application”). 

28 calendar days after the Notice Date. 

Deadline for objecting to the Fee and Expense 

Application. 

56 calendar days after the Notice Date. 

Deadline to file reply papers in support of the 

Fee and Expense Application. 

77 calendar days after the Notice Date. 

Hearing regarding the Fee and Expense 

Application. 

At the Court’s convenience, but not earlier than 

90 calendar days after the Notice Date. 

Plaintiffs’ Proposed Order Approving the Form and Manner of Notice, submitted herewith, 

incorporates these previously approved dates. For the Court’s convenience, if the Proposed Order is 

entered on November 11, 2013, the schedule would result in the following dates: 

 If Order Entered on 

November 11, 2013: 

Notice mailed or e-mailed to 

Class Members identified on 

Exhibit A to the Judgment. 

15 calendar days after the Court 

enters an order approving the 

Notice (hereinafter, “the Notice 

Date”). 

November 26, 2013 

Deadline for filing motion for an 

award of attorney’s fees and nontaxable costs and Lead Plaintiffs’ 

application for reimbursement of 

expenses (“the Fee and Expense 

Application”). 

28 calendar days after the Notice 

Date. 

December 24, 2013 

Deadline for objecting to the Fee 

and Expense Application. 

56 calendar days after the Notice 

Date. 

January 21, 2014 

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Deadline to file reply papers in 

support of the Fee and Expense 

Application. 

77 calendar days after the Notice 

Date. 

February 11, 2014 

Hearing regarding the Fee and 

Expense Application. 

At the Court’s convenience, but 

not earlier than 90 calendar days 

after the Notice Date. 

on or after February 24, 

2014 

Plaintiffs respectfully request that the Court enter the Proposed Order Approving the Form 

and Manner of Notice. 

DATED: November 7, 2013 Respectfully submitted, 

ROBBINS GELLER RUDMAN 

 & DOWD LLP 

MICHAEL J. DOWD (135628) 

SPENCER A. BURKHOLZ (147029) 

DANIEL S. DROSMAN (200643) 

LAWRENCE A. ABEL (129596) 

MAUREEN E. MUELLER (253431) 

s/ MICHAEL J. DOWD 

MICHAEL J. DOWD 

655 West Broadway, Suite 1900 

San Diego, CA 92101 

Telephone: 619/231-1058 

619/231-7423 (fax) 

ROBBINS GELLER RUDMAN 

 & DOWD LLP 

LUKE O. BROOKS (90785469) 

JASON C. DAVIS (253370) 

Post Montgomery Center 

One Montgomery Street, Suite 1800 

San Francisco, CA 94104 

Telephone: 415/288-4545 

415/288-4534 (fax) 

Lead Counsel for Plaintiffs 

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MILLER LAW LLC 

MARVIN A. MILLER 

LORI A. FANNING 

115 S. LaSalle Street, Suite 2910 

Chicago, IL 60603 

Telephone: 312/332-3400 

312/676-2676 (fax) 

Liaison Counsel 

LAW OFFICES OF LAWRENCE G. 

 SOICHER 

LAWRENCE G. SOICHER 

110 East 59th Street, 25th Floor 

New York, NY 10022 

Telephone: 212/883-8000 

212/355-6900 (fax) 

Attorneys for Plaintiff 

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I, the undersigned, declare: 

1. That declarant is and was, at all times herein mentioned, a citizen of the United States 

and employed in the City and County of San Diego, State of California, over the age of 18 years, and 

not a party to or interested party in the within action; that declarant’s business address is 655 W. 

Broadway, Suite 1900, San Diego, California 92101. 

2. That on November 7, 2013, declarant served by electronic mail and by U.S. Mail to 

the parties the following documents: 

MOTION FOR AN ORDER APPROVING THE FORM AND MANNER OF NOTICE

The parties’ e-mail addresses are as follows: 

Tkavaler@cahill.com

Pfarren@cahill.com

Dowen@cahill.com

Jhall@cahill.com 

Pclement@bancroftpllc.com 

Zhudson@bancroftpllc.com 

Mrakoczy@skadden.com 

Rstoll@skadden.com 

Mmiller@MillerLawLLC.com 

Lfanning@MillerLawLLC.com

and by U.S. Mail to: 

Lawrence G. Soicher, Esq. 

Law Offices of Lawrence G. Soicher 

110 East 59th Street, 25th Floor 

New York, NY 10022 

I declare under penalty of perjury that the foregoing is true and correct. Executed this 7th 

day of November, 2013, at San Diego, California. 

DEBORAH S. GRANGER 

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