IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

AMY WIGINTON, KRISTINE MORAN, 

NORMA PLANK FETHLER, as successor 

in interest to DONDI PLANK, ANDREA 

COREY, and OLIVIA KNAPP, individually 

and on behalf of all persons similarly 

situated, 

Plaintiffs, 

v. 

CB RICHARD ELLIS, INC. 

Defendant. 

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Case No.: 02 CV 6832 

Judge Wayne R. Andersen 

Magistrate Judge Martin C. Ashman 

PLAINTIFFS’ UNOPPOSED MOTION FOR LEAVE TO FILE MOTION FOR FINAL 

APPROVAL OF SETTLEMENT IN EXCESS OF FIFTEEN PAGES

Plaintiffs Amy Wiginton, Kristine Moran, Norma Plank Fethler, as successor in interest 

to Dondi Plank, Andrea Corey, and Olivia Knapp, by their attorneys, respectfully request leave 

to file a Memorandum in support of their Motion for Final Approval of Settlement in excess of 

fifteen (15) pages. As grounds for the foregoing, plaintiffs state as follows: 

1. Plaintiffs’ motion for final approval of settlement is being filed with the Court on 

January 4, 2008 in advance of the fairness hearing scheduled for January 9, 2008. 

2. LR 7.1 provides that briefs may not exceed fifteen (15) pages. This Court’s Case 

Management Procedures likewise provide the same. 

3. Plaintiffs seek certification of a nationwide Settlement Class and final approval of 

the Settlement reached by the Parties, for which preliminary approval has already been granted. 

Given the extensive factual background and legal arguments necessary at this stage, Plaintiffs 

cannot fully or adequately address all such issues in fifteen pages. 

Case: 1:02-cv-06832 Document #: 327 Filed: 01/04/08 Page 1 of 4 PageID #:3171
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4. Plaintiffs’ counsel has conferred with defendant’s counsel concerning this motion 

and defendant does not oppose it. 

WHEREFORE plaintiffs respectfully request that this Court grant them leave to file their 

motion for class certification in excess of fifteen (15) pages, and any other relief that this Court 

deems just and proper. 

DATED: January 4, 2008 Respectfully Submitted, 

AMY WIGINTON, KRISTINE MORAN, 

NORMA PLANK FETHLER, as successor 

in interest to DONDI PLANK, ANDREA 

COREY, and OLIVIA KNAPP, individually 

and on behalf of all others similarly situated, 

Plaintiffs 

By: /s/ Kenneth A. Wexler 

One of Their Attorneys 

Kenneth A. Wexler 

Jennifer Fountain Connolly 

Amber M. Nesbitt 

Wexler Toriseva Wallace LLP 

55 W. Monroe Street, Suite 3300 

Chicago, IL 60603 

(312) 346-2222 – Telephone 

Elizabeth A. Fegan 

Hagens Berman Sobol Shapiro LLP 

820 North Boulevard, Suite B 

Oak Park, IL 60301 

(708) 776-5600 – Telephone 

Steve W. Berman 

Nicholas Styant-Browne 

Hagens Berman Sobol Shapiro LLP 

1301 Fifth Avenue, Suite 2900 

Seattle, WA 98101 

(206) 623-7292 – Telephone 

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JoDee Favre 

Favre Law Office, LLC 

5005 W. Main Street 

Belleville, IL 62226 

(618) 257-8605 – Telephone 

Daniel E. Gustafson 

Karla M. Gluek 

Renae Steiner 

Gustafson Gluek PLLC 

650 Northstar East 

608 Second Avenue S. 

Minneapolis, MN 55402 

(612) 333-8844 – Telephone 

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CERTIFICATE OF SERVICE

I, Kenneth A. Wexler, hereby certify that a copy of the foregoing Plaintiffs’ Unopposed 

Motion for Leave to File Motion for Final Approval of Settlement in Excess of Fifteen Pages

was electronically filed on January 4, 2008. Those attorneys who are registered with the 

Electronic Filing System may access these filings through the Court’s System and notice of these 

filings will be sent to these parties by operation of the Court’s Electronic Filing System. 

/s/ Kenneth A. Wexler 

Kenneth A. Wexler 

Wexler Toriseva Wallace LLP 

55 W. Monroe Street, Suite 3300 

Chicago, IL 60603 

(312) 346-2222 – Telephone 

(312) 346-0022 – Facsimile 

kaw@wtwlaw.com 

Case: 1:02-cv-06832 Document #: 327 Filed: 01/04/08 Page 4 of 4 PageID #:3174