BUTTACI LEARDI & WERNER LLC 

212 Carnegie Center, Suite 202 

Princeton, NJ 08540 

609-799-5150

609-799-5180 FAX

www.buttacilaw.com

P R I N C E T O N , N J ● T A R R Y T O W N , N Y

JOHN W. LEARDI, ESQ.

MEMBER, NJ & NY BARS

DIRECT EXTENSION: 115

E-MAIL: JWLEARDI@BUTTACILAW.COM

February 10, 2021

VIA ELECTRONIC CASE FILING

Hon. John Michael Vazquez, U.S.D.J.

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW JERSEY

Martin Luther King Building & U.S. Courthouse

50 Walnut Street, Room 4015

Newark, NJ 07101

Re: Integrated Orthopedics Inc. v. UnitedHealth Group

Case No.: 11-cv-425 (ES) (CLW)

Dear Judge Vazquez:

Our firm, along with Zuckerman Spaeder LLP, is Class Counsel for Plaintiff in the 

above-referenced matter. Together with Defendants, we write jointly to request the adjustment of 

one deadline set forth in the Court’s October 15, 2020 Findings and Order Granting Preliminary 

Approval to Proposed Settlement, Approving Form and Dissemination of Class Notice, and 

Setting Date for Hearing on Final Approval Order (Dkt. 423) (the “Preliminary Approval 

Order”). 

The Preliminary Approval Order directs that any responses to objections to the proposed 

settlement be filed no more than 14 days before the Fairness Hearing, and for Plaintiff to file its 

motion for final approval no more than 7 days before the Fairness Hearing. Dkt. 423 ¶ 10.

One objection to the settlement was filed. Under the current schedule, as modified by the 

Court on February 9 (Dkt. 426) (moving fairness hearing to February 25, 2021), responses to the 

objection are due on February 11. Class Counsel have been conferring with counsel for the 

objector. Those discussions are ongoing and may result in resolution or withdrawal of the 

objection. To give the parties more time to address the objection with the objector, the parties 

respectfully request that the objection response date be moved to match the February 18 deadline 

for Plaintiff’s submission of the motion for final approval. If necessary, Plaintiff will respond to 

the objection as part of that motion and Defendants may also respond to the objection at that 

time. Because the ongoing discussions may resolve the objection, and neither the objector nor 

any other party will be prejudiced by this adjustment to the schedule, good cause exists for the 

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Hon. John Michael Vazquez, U.S.D.J.

February 10, 2021

Page 2 of 2

requested modification.

The parties jointly and respectfully request that the Court so order the requested 

adjustment to the Preliminary Approval Order. 

Thank you in advance for Your Honor’s consideration.

Respectfully submitted,

BUTTACI LEARDI & WERNER, LLC

/s/ John W. Leardi

John W. Leardi

A Member of the Firm

JWL/

cc: All Counsel of Record (via electronic mail only)

IT IS SO ORDERED THIS 7+DAY OF FEBRUARY 2021

_______________________________________

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United States District Judge 

______________________________________

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United States District J dge

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