Page 1 of 3

The Wolf Law Firm, LLC

1520 U.S. Hwy 130 – Suite 101

North Brunswick, NJ 08902

Tel: (732) 545-7900

Fax: (732) 545-1030

Philip D. Stern, Esq.

Philip D. Stern & Associates, LLC

Attorneys at Law

697 Valley Street, Suite 2d

Maplewood, NJ 07040

(973) 379-7500

Attorneys for Plaintiff and the putative class

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

NEWARK VICINAGE

THOMAS C. WILLIAMS, on behalf of 

himself and those similarly situated,

Plaintiff,

vs.

THE CBE GROUP, INC.,

Defendant.

Civil Action No. 2:11-cv-3680-PS

DECLARATION OF 

ANDREW R. WOLF, ESQ.

Andrew R. Wolf, Esq., of full age, by way of Declaration in lieu of Affidavit, states:

1. I am an Attorney at Law of the State of New Jersey, and the sole member of the 

Wolf Law Firm, LLC with offices located at 1520 U.S. Highway 130, Suite 101, North 

Brunswick, New Jersey. 

2. My firm, along with the Philip D. Stern and Associates, represents Plaintiff on 

behalf of himself and all others similarly situated in this matter. I have personal knowledge of 

the facts stated herein.

3. I make this Certification in support of preliminary approval of the class action 

settlement including certifying a Fed. R. Civ. P. 23(b)(3) settlement class, appointing Plaintiff's 

Case 2:11-cv-03680-PS Document 27-2 Filed 03/01/12 Page 1 of 3 PageID: 135
Page 2 of 3

counsel as class counsel, appointing Plaintiff as the class representative and scheduling a 

Fairness Hearing.

4. Based on the claims alleged in this matter, we believe that certification of a Fed. 

R. Civ. P. 23(b)(3) class and the proposed settlement is appropriate. 

5. I have been personally involved in this matter, including the investigation of 

claims, drafting, reviewing and editing of pleadings and briefs, legal research, settlement 

negotiations and many other aspects of the litigation. I am experienced in handling complex 

litigation such as this, and I have been certified as class counsel in 53 other matters. 

6. Plaintiff filed this action on June 24, 2011. Defendant filed an answer on August 

8, 2011. Defendant subsequently moved for judgment on the pleadings, and the Court denied the 

motion in an order and opinion filed December 22, 2011. The parties thereafter began settlement 

negotiations and reached a settlement as to all issues other than attorneys' fees. Subsequently, the 

parties negotiated and agreed upon an amount for attorneys' fees. The final settlement agreement 

was signed on February 23, 2012.

7. A copy of the Class Action Settlement Agreement is attached as Exhibit A. A 

copy of the proposed form of Notice, which was modeled on the template notices created by the 

Federal Judicial Center, is attached as Exhibit B.

8. Based on my experience, I believe that the settlement is fair, reasonable and 

adequate, particularly in a case alleging only statutory damages under the FDCPA.

9. My firm and the attorneys involved in this matter are experienced in cases 

involving complex litigation issues concerning consumer protection statutes—including the Fair 

Debt Collection Practices Act (FDCPA), regulations and violations thereof, and the complex 

issues related to litigating putative class action cases. I have personally been certified as class 

counsel in 59 cases, more than twelve of which were class actions involving violations of the 

FDCPA. A list of the cases where I have been certified as class counsel is attached as Exhibit 

C.

10. The law firms and attorneys involved in this matter are also experienced with the 

complex issues of obtaining class certification, obtaining and verifying information related to 

class members, supervising and monitoring the provision of Notice to class members. The law 

firms and attorneys involved in this matter are also experienced in negotiating complex class 

action settlements, obtaining court approval of class action settlements and implementing, 

Case 2:11-cv-03680-PS Document 27-2 Filed 03/01/12 Page 2 of 3 PageID: 136
Page 3 of 3

monitoring and supervising the class action settlements after preliminary approval and after final 

approval of class action settlements. Mr. Wolfe, Mr. Gardner, Mr. Ricci and I are members of 

the National Association of Consumer Advocates and have concentrated our practices in the area 

of consumer law. A copy of the profiles of the attorneys in my firm from our website is attached 

as Exhibit D. 

11. My firm has devoted all resources necessary to litigate this case to date and will 

continue to commit the time and resources necessary until the case is finally resolved. My office 

has more than adequate resources to prosecute this case, including several attorneys, sufficient 

support staff experienced in communicating with class members, multiple telephone lines for 

handling communications or questions from class members, and a record of successfully 

completed class actions.

12. My firm intends to vigorously represent the interests of the putative class. We are 

not aware of any possible conflicts of interest between Plaintiff and their counsel or the putative 

class.

In accordance with 28 U.S.C. §1746, I declare under penalty of perjury under the laws 

of the United States of America that the foregoing is true and correct.

s/Andrew R. Wolf___________

ANDREW R. WOLF, ESQ.

Dated: March 1, 2012

Case 2:11-cv-03680-PS Document 27-2 Filed 03/01/12 Page 3 of 3 PageID: 137