UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

KIMBERLEE WILLIAMS, et al.

Plaintiffs,

vs.

BASF CATALYSTS LLC, et al.

Defendants.

No. 2:11-cv-01754 (ES) (JAD)

CIVIL ACTION

Consent Order Amending Deadlines 

WHEREAS, on September 3, 2020, the Court entered an Order 

Preliminarily Approving the proposed Class Action Settlement of this 

matter (ECF No. 623); and

WHEREAS, the Court’s Preliminary Approval Order established 

a schedule of deadlines for notice, filing of claims and other steps to 

effectuate the Settlement Agreement and Plan of Distribution; and

WHEREAS, on September 17, 2020, the Notice Administrator 

commenced providing direct notice by United States first class mail to

living putative class members, relatives of deceased putative class 

members and attorneys who had represented putative class members in 

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Underlying Lawsuits, and in addition provided notice by publication, 

all in compliance with ECF No. 623; and

WHEREAS, the Notice Administrator has reported that 84.6% of 

Class Members have been reached directly and through at least one 

relative; and 

WHEREAS, despite their due diligence, putative class members 

and counsel seeking to file claims on behalf of putative class members 

have encountered unforeseen difficulties because of the COVID-19 

pandemic in obtaining the necessary information and documentation to 

file claims by the claims deadline originally set forth in the Preliminary 

Approval Order ( ECF No. 623); and

WHEREAS, upon learning of the difficulties being encountered 

the Special Master directed the Parties to the Settlement Agreement to 

forthwith meet and confer on the situation; and

WHEREAS, in light of the foregoing, the Parties have agreed that 

a reasonable extension of deadlines established in the Preliminary 

Approval Order are required to ameliorate the difficulties in the claims 

filing and approval process; and

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WHEREAS, the Parties through respective counsel have 

consented to the entry of this Order amending the Preliminary 

Approval Order ;

IT IS on this day of January, 2021, hereby ORDERED that 

the Deadlines established in ECF No. 623 are hereby amended as 

follows: 

Objection Submission Deadline February 16, 2021

Opt-Out Deadline February 16, 2021

Opt-Out Revocation Deadline March 2, 2021

Final Op-Out List Generated March 8, 2021

Claims Filing Deadline March 16, 2021

Document Submission Deadline April 20, 2021

Objection Response Deadline June 29, 2021

Motion for Final Approval Deadline June 29, 2021

The Amended Deadlines established in this Order shall be 

prominently displayed on the Settlement Administration Website. 

The Final Approval Fairness Hearing remains scheduled before 

this Court on July 29, 2021, at 10:00 am. 

11th

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BY THE COURT

___________________________

Hon. Joseph A. Dickson

United States Magistrate Judge

/s/ Joseph A. Dickson

Dated: January 11, 2021

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