UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

JOINT MOTION FOR EXTENSION OF TIME TO FILE A STIPULATION OF 

SETTLEMENT AND MOTION FOR PRELIMINARY APPROVAL

Court-appointed Lead Plaintiff Fadi E. Rahal (“Lead Plaintiff”), and Defendants Groupon, 

Inc., Rich Williams, and Melissa Thomas (the “Defendants,” and collectively with Lead Plaintiff, 

the “Parties”), by and through their respective counsel, respectfully move for an order extending 

the deadline for the Parties to file a stipulation of settlement and to move for preliminary approval 

of that settlement:

1. Lead Plaintiff’s Motion for Preliminary Approval of Settlement is due to be filed

on June 20, 2022, per the Court’s Minute Entry Order, dated May 10, 2022 [Dkt. No. 103].

2. June 20, 2022 is a legal public holiday.

3. The Parties have been diligently working on the stipulation of settlement and 

exhibits thereto, including: (a) [Proposed] Order Preliminarily Approving Settlement and 

Providing Notice; (b) Notice of Class Action Settlement; (c) Proof of Claim Form and Release; 

(d) Summary Notice of Class Action Settlement; and (e) [Proposed] Judgment Approving Class 

Action Settlement. However, due to the intervening public holiday and the many constituencies 

involved in the review and approval of the settlement terms, the Parties seek additional time to 

LAZAR MACOVSKI, Individually and On 

Behalf of All Others Similarly Situated,

Plaintiff,

v.

GROUPON, INC., RICH WILLIAMS, and 

MELISSA THOMAS,

Defendants.

Case No. 1:20-cv-02581

Honorable Matthew F. Kennelly

Case: 1:20-cv-02581 Document #: 104 Filed: 06/14/22 Page 1 of 3 PageID #:1286
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finalize the stipulation of settlement and exhibits thereto. 

4. Accordingly, the Parties respectfully request that the Court extend the deadline for 

the Parties to file their stipulation of settlement and move for preliminary approval by 7 days, to 

June 27, 2022.

5. This is the Parties’ first request to extend this deadline.

WHEREFORE, Lead Plaintiff Fadi E. Rahal, and Defendants Groupon, Inc., Rich 

Williams, and Melissa Thomas respectfully request this Court enter an Order extending the time 

in which they must file a stipulation of settlement and Lead Plaintiff must move for preliminary 

approval to June 27, 2022. 

Respectfully submitted,

June 14, 2022

SKADDEN, ARPS, SLATE, MEAGHER & 

FLOM LLP

/s/ Matthew R. Kipp

Matthew R. Kipp

Andrew J. Fuchs

Laura Bernescu

155 North Wacker Drive

Chicago, Illinois 60606

(312) 407-0700

Email: matthew.kipp@skadden.com

andrew.fuchs@skadden.com

laura.bernescu@skadden.com

Counsel for Defendants

GLANCY PRONGAY & 

MURRAY LLP

/s/ Leanne H. Solish

Robert V. Prongay (admitted pro hac vice)

Kara M. Wolke (admitted pro hac vice)

Leanne H. Solish (admitted pro hac vice)

Christopher Fallon (admitted pro hac vice)

1925 Century Park East, Suite 2100

Los Angeles, CA 90067

Telephone: (310) 201-9150

Email: rprongay@glancylaw.com

kwolke@glancylaw.com

lsolish@glancylaw.com

cfallon@glancylaw.com

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KIRBY MCINERNEY LLP

Ira M. Press (admitted pro hac vice)

Andrew M. McNeela (admitted pro hac vice)

Thomas W. Elrod (admitted pro hac vice)

250 Park Avenue, Suite 820

New York, NY 10177

Telephone: (212) 371-6600

Email: ipress@kmllp.com 

amcneela@kmllp.com

telrod@kmllp.com

Counsel for Lead Plaintiff and Lead Counsel 

for the Proposed Class

POMERANTZ LLP

Patrick V. Dahlstrom

Louis C. Ludwig

10 South LaSalle Street, Suite 3505

Chicago, IL 60603

Telephone: (312) 377-1181

Email: pdahlstrom@pomlaw.com

lcludwig@pomlaw.com

Liaison Counsel for Lead Plaintiff and the 

Proposed Class

Case: 1:20-cv-02581 Document #: 104 Filed: 06/14/22 Page 3 of 3 PageID #:1288