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Snell & Wilmer

L.L.P.

LAW OFFICES

One Arizona Center, 400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

602.382.6000

Thomas A. Saenz* (Cal. Bar. No. 159430)

Andrés R. Holguin-Flores* (Cal. Bar No. 305860)

MEXICAN AMERICAN LEGAL

DEFENSE AND EDUCATIONAL FUND

634 S. Spring St., 11th Fl.

Los Angeles, CA 90014

Telephone: (213) 629-2512 

E-mail: tsaenz@maldef.org

aholguin-flores@maldef.org

*admitted pro hac vice

Attorneys for Plaintiffs

Additional Counsel Listed on Next Page

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Jane V.; John A.; John E.; Jane F.; John 

D.; John M.; Jane N.; and John W.; 

individually and on behalf of all others 

similarly situated,

Plaintiffs,

v.

Motel 6 Operating L.P., a limited 

partnership; G6 Hospitality LLC, a limited 

liability company, dba Motel 6; and Does 

1-10,

Defendants.

No.: 2:18-cv-00242-DGC 

JOINT STATUS REPORT

Case 2:18-cv-00242-DGC Document 92 Filed 03/29/21 Page 1 of 9
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Snell & Wilmer

L.L.P.

LAW OFFICES

One Arizona Center, 400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

602.382.6000

Nina Perales* (Tex. Bar No. 24005046)

MEXICAN AMERICAN LEGAL

DEFENSE AND EDUCATIONAL FUND

110 Broadway St., Suite 300

San Antonio, TX 78205

Telephone: (210) 224-5476

E-mail: nperales@maldef.org

Daniel R. Ortega, Jr. (Ariz. Bar No. 005015)

ORTEGA LAW FIRM, P.C.

361 East Coronado Rd., Suite 101

Phoenix, AZ 85004-1525

Telephone: (602) 386-4455

E-mail: danny@ortegalaw.com

Attorneys for Plaintiffs

Don Bivens (Ariz. Bar. No. 005134)

Patricia Lee Refo (Ariz. Bar. No. 017032)

SNELL & WILMER, LLP

One Arizona Center

400 E. Van Buren St., Suite 1900

Phoenix, Arizona 85004-2002

Telephone: 602.382.6000

Facsimile 602.382.6070

Email: dbivens@swlaw.com

prefo@swlaw.com

Stacie E Tobin* (MD Bar No. 11331)

VENABLE LLP

750 E. Pratt Street, Suite 900

Baltimore, MD 21201

Telephone: (410) 244-7878

Email: SETobin@venable.com

Peter J. Kadzik* (D.C. Bar No. 964007)

VENABLE LLP

600 Massachusetts Ave. NW

Washington, DC 20001

Telephone: (202) 344-4147

Email: PJKadzik@Venable.com

Donald B. Verrilli, Jr.* (D.C. Bar. No. 420434)

MUNGER, TOLLES & OLSON LLP

1155 F St. NW-- 7th Floor

Washington, DC 20004

Telephone: (202) 220-1100

Email: michael.desanctis@mto.com

* admitted pro hac vice

Attorneys for Defendants

Case 2:18-cv-00242-DGC Document 92 Filed 03/29/21 Page 2 of 9
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Snell & Wilmer

L.L.P.

LAW OFFICES

One Arizona Center, 400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

602.382.6000

In accordance with the Court’s order granting Final Settlement Approval 1 (“the 

Agreement”) (Doc. 87), and the Consent Decree (Doc. 88), Plaintiffs Jane V., John A., John 

E., Jane F., John D., John M., Jane N., and John W. (“Plaintiffs”) and Defendants Motel 6 

Operating L.P. (“Motel 6 Operating”) and G6 Hospitality, LLC, dba Motel 6 (“G6 

Hospitality”) (collectively “Motel 6” or “Defendants”), jointly file this Status Report. 

Under the Sections VI.A and XI.C of the Agreement, the Parties are required to 

“conduct an annual status conference with the Settlement Administrator, with a report to 

the Court following the status conference to discuss the status of implementation of the 

[A]greement.” The Parties conducted the requisite first annual conference (the 

“Conference”) with the Settlement Administrator on March 4, 2021. In the Conference, the 

Settlement Administrator reported orally that it has distributed all of the settlement funds. 

The Parties submit the attached letter from the Settlement Administrator that provides 

further detail about the settlement fund distribution. See Exhibit 1 (Letter from Tara Trapani 

on behalf of Arden Claims Services). 

Also during the Conference, Motel 6 reported that it has implemented the equitable 

provisions of the Agreement and provides below the dates as to which it implemented each. 

First, under Section X.A.1. of the Agreement, Motel 6 implemented the following 

guest privacy program and policy (the “Policy”) by October 2019 and on later dates as 

specifically set forth below:

• It established a 24-Hour Hotline to assist employees at Motel 6 Entities when 

they receive any request for Guest Information from Federal Immigration 

Authorities. See Agreement § X.A.1.a. Motel 6 maintains the 24-Hour 

Hotline, which is still in operation. 

• Motel 6 employees shall not share Guest Information with Federal 

Immigration Authorities without a judicially enforceable warrant or 

1 All initial-capped words refer to the terms and definitions in the Third Amended 

Settlement Agreement attached as an exhibit to the Court’s order granting Final Settlement 

Approval, except as stated herein.

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Snell & Wilmer

L.L.P.

LAW OFFICES

One Arizona Center, 400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

602.382.6000

subpoena, except where the Federal Immigration Authority articulates a 

credible reason to believe that a Guest, employee, or other individual is in 

imminent danger. See Agreement § X.A.1.b.i. In accordance with this term, 

Motel 6 implemented its policy and informed Motel 6 employees that with

respect to all other warrants or subpoenas presented by Federal Immigration 

Authorities, they “shall not share Guest Information with Federal 

Immigration Authorities until such warrants or subpoenas have been sent to 

Defendants’ legal department or other individuals designated by Defendants, 

who will have been trained to comply with this Policy and to address requests 

from Federal Immigration Authorities, and until such persons authorize the 

disclosure of Guest Information.” See Agreement § X.A.1.b.ii.

• Motel 6 had trained its employees about the 24-Hour Hotline by November 

24, 2019 and conducted re-training in the summer of 2020, with a completion 

date of August 31, 2020. It will re-train its employees each year through the 

duration of the Consent Decree and will provide training on a rolling basis to 

new employees. See Agreement § X.1.b.iii. 

• By September 2019, Motel 6 established brand standards requiring that 

Franchised Locations adopt and implement the policies and procedures 

described above. See Agreement § X.A.1.b.iv.

• In the second quarter of 2019, Motel 6 created an online mechanism for any

person at a Motel 6 Location to submit a report when he or she believes that 

Guest Information has been provided to Federal Immigration Authorities or 

that this Policy has been violated in any manner (a Compliance Complaint”). 

Further, any person who submits a Compliance Complaint may do so 

anonymously. See Agreement § X.A.1.b.v. The online mechanism remains 

in place today.

• For each employee at an Operated Location who has the ability to make Guest 

Information available, it has provided training about the Policy and their

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Snell & Wilmer

L.L.P.

LAW OFFICES

One Arizona Center, 400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

602.382.6000

responsibilities with regard to the Policy, including the purpose and 

procedures regarding the 24-Hour Hotline, such as when it is appropriate and 

necessary to contact the 24-Hour Hotline. See Agreement § X.A.1.c. Motel 

6 had conducted this training by November 24, 2019 and conducted retraining in the summer of 2020, which was completed by August 31, 2020. It 

will provide this training again annually through the duration of the Consent 

Decree and on a rolling basis to new employees.

Second, following Section XI.A of the Agreement, Defendant Motel 6 has retained 

since July 2019 the following documents: (1) Compliance Complaints; (2) Incident 

Reports; and (3) Logs of any calls made by Defendant Motel 6’s employees (including

employees at Operated Locations) to the 24-Hour Hotline. See Agreement § XI.A.

DATED this 29th day of March, 2021.

MEXICAN AMERICAN LEGAL DEFENSE 

AND EDUCATION FUND, INC.

By: /s/ Andrés Holguin-Flores (w/permission)

Thomas A. Saenz

Andrés Holguin-Flores

Nina Perales

Daniel R. Ortega, Jr.

Attorneys for Plaintiffs

SNELL & WILMER L.L.P.

By: /s/ Patricia Lee Refo

Donald W. Bivens

Patricia Lee Refo

One Arizona Center

400 E. Van Buren

Phoenix, AZ 85004-2202

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Snell & Wilmer

L.L.P.

LAW OFFICES

One Arizona Center, 400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

602.382.6000

MUNGER, TOLLES & OLSON, LLP

Donald B. Verrilli, Jr.

VENABLE LLP

Peter J. Kadzik

Stacie E. Tobin

Attorneys for Defendants

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LAW OFFICES

One Arizona Center, 400 E. Van Buren, Suite 1900

Phoenix, Arizona 85004-2202

602.382.6000

CERTIFICATE OF SERVICE

I certify that on March 29, 2021, I electronically transmitted the foregoing document 

and any attachments to the Clerk’s Office using the CM/ECF System and for filing 

transmittal of a Notice of Electronic Filing to all CM/ECF registrants in this matter.

s/ Martin Lucero

Case 2:18-cv-00242-DGC Document 92 Filed 03/29/21 Page 7 of 9
EXHIBIT 1

Case 2:18-cv-00242-DGC Document 92 Filed 03/29/21 Page 8 of 9
322 Main Street ◆ Port Washington, NY 11050 ◆ 877.623.2703 ◆ fax: 516.888.3501 ◆ www.ardenclaims.com

March 4, 2021 

Via E‐Mail Only

Stacie E. Tobin, Esq. 

Venable LLP 

750 E Pratt Street 

Suite 900 

Baltimore, MD 21202 

Andres Holguin-Flores, Esq. 

MALDEF 

634 S Spring Street 

11th Floor 

Los Angeles, CA 90014 

Re:			Jane V., et al. v. Motel 6 Operating LP, et al.

Ms. Tobin/Mr. Holguin-Flores, 

Arden Claims Service LLC (“Arden Claims”), the Court Appointed Claims Administrator, hereby represents 

the following at the annual status conference: 

- $8.5 million was funded into the Gross Settlement Account by the Defendants 

- On April 2, 2020, Arden Claims issued 1,988 award payments to participating claimants 

- The amount awarded for all claims totaled $5,452,371.00 

- The remaining amount was distributed on June 22, 2020 to the four (4) selected Cy Pres recipients in 

accordance with the allocation prescribed in the Settlement Agreement 

- By the end of the acceptance period (120 days after check issuance) all but 161 - $75 awards were cashed 

- The amount in uncashed funds in the account totaled $12,075, which was then distributed to Cy Pres in the 

same manner and allocation as the initial distribution. This distribution was effectuated on November 12, 

2020 

- As of the date of this conference, there is a zero balance in the QSF Account 

- The final tax return for the QSF will be filed by April 15th of the current year 

Please feel free to contact me should you have any questions or if you require any additional information. 

Thank you. 

Sincerely, 

 

 

Tara Trapani 

Exec. Dir. of Information and Client Services

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