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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

JULIA ROSSI, DELILAH PARKER and 

KELVIN HOLMES, Individually and on 

Behalf of All Others Similarly Situated, 

Plaintiffs, 

v. 

 

CLAIRE’S STORES, INC.; CLAIRE’S 

BOUTIQUES, INC.; and CBI 

DISTRIBUTING CORP., 

Defendants. 

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Case No.: 1:20-cv-5090 

Hon. Andrea R. Wood, presiding 

Hon. Magistrate Heather K. McShain 

UNOPPOSED MOTION TO CONTINUE PLAINTIFFS’ DEADLINE TO FILE MOTION 

FOR PRELIMINARY APPROVAL OF SETTLEMENT 

 Plaintiffs Julia Rossi, Delilah Parker, and Kelvin Holmes (collectively, “Plaintiffs”) bring 

this unopposed motion to continue Plaintiffs’ deadline to file a motion for preliminary approval1

of their proposed class settlement with Defendants Claire’s Stores, Inc., Claire’s Boutiques, Inc., 

and CBI Distributing Corp. (collectively, “Defendants” and, collectively with Plaintiffs, the 

“Parties”). Defendants do not oppose this motion. (Declaration of Bradley K. King, attached, ¶ 2.) 

 As indicated in the Parties’ Joint Status Report and Notice of Settlement in Principle (Dkt. 

42), the Parties reached a settlement in principle after a full-day mediation session with Bennett 

G. Picker, Esq. on March 23, 2021. Since then, the Parties have worked diligently to draft the 

settlement agreement and related exhibits and anticipate being able to finalize and execute the 

agreement in the coming weeks. In addition, Plaintiffs have been diligently preparing their motion 

for preliminary approval and supporting documents. 

1 As ordered in the Court’s April 20, 2021 Minute Entry, Dkt. 43. 

Case: 1:20-cv-05090 Document #: 44 Filed: 05/07/21 Page 1 of 3 PageID #:370
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 Despite these diligent efforts, a modest extension of the current deadline is needed to ensure 

adequate time for the Parties to finalize their settlement and prepare all requisite documents for 

filing. Consequently, the Parties respectfully request an additional 30 days to file the preliminary 

approval motion, settlement agreement, and supporting documents. 

CONCLUSION 

Plaintiffs respectfully move the Court, without opposition, to continue the May 17, 2021 

deadline to file a motion for preliminary approval of settlement by 30 days to June 16, 2021. 

Respectfully submitted, 

Dated: May 7, 2021 /s/ Bradley K. King 

Bradley K. King 

bking@ahdootwolfson.com 

AHDOOT & WOLFSON, PC 

2600 West Olive Avenue, Suite 500 

Burbank, California 91505 

Tel: (310) 474-9111 

Fax: (310) 474-8585 

M. Anderson Berry 

aberry@justice4you.com 

CLAYEO C. ARNOLD, 

A PROFESSIONAL LAW CORP. 

865 Howe Avenue 

Sacramento, California 95825 

Tel: (916) 777-7777 

Fax: (916) 924-1829 

Interim Co-Lead Counsel for Plaintiffs 

Case: 1:20-cv-05090 Document #: 44 Filed: 05/07/21 Page 2 of 3 PageID #:371
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CERTIFICATE OF SERVICE 

I hereby certify that on May 7, 2021, the foregoing Unopposed Motion to Continue 

Plaintiffs’ Deadline to File Motion for Preliminary Approval of Settlement with supporting 

declaration was electronically filed with the Clerk of the United States District Court for the 

Northern District of Illinois, using the CM/ECF system, which will send notification of the filing 

to all attorneys of record. 

/s/ Bradley K. King 

Case: 1:20-cv-05090 Document #: 44 Filed: 05/07/21 Page 3 of 3 PageID #:372