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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 1 of 12
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`Rafey S. Balabanian (SBN 315962)
`rbalabanian@edelson.com
`Todd Logan (SBN 305912)
`tlogan@edelson.com
`Brandt Silver-Korn (SBN 323530)
`bsilverkorn@edelson.com
`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, California 94111
`Tel: 415.212.9300 / Fax: 415.373.9435
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`Attorneys for Plaintiffs
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`Additional Counsel Listed on Signature Page
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
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`IN RE: APPLE INC. APP STORE
`SIMULATED CASINO-STYLE GAMES
`LITIGATION
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`IN RE: GOOGLE PLAY STORE
`SIMULATED CASINO-STYLE GAMES
`LITIGATION
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`Case No. 5:21-md-02985-EJD
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`AMENDED [PROPOSED] ORDER
`GRANTING UNOPPOSED MOTION
`FOR PRETRIAL CONSOLIDATION
`AND APPOINTMENT OF INTERIM
`LEAD COUNSEL AND PLAINTIFFS’
`EXECUTIVE COMMITTEE [DKT. 29]
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`Judge: Hon. Edward J. Davila
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`Case No. 5:21-md-03001-EJD
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`AMENDED [PROPOSED] ORDER
`GRANTING UNOPPOSED MOTION
`FOR PRETRIAL CONSOLIDATION
`AND APPOINTMENT OF INTERIM
`LEAD COUNSEL AND PLAINTIFFS’
`EXECUTIVE COMMITTEE [DKT. 9]
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`
`
`Judge: Hon. Edward J. Davila
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
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`1
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 2 of 12
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`KATHLEEN WILKINSON, NANCY
`URBANCZYK, and LAURA
`PERKINSON,
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`Plaintiffs,
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`v.
`FACEBOOK, INC.,
`Defendant.
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`Case No. 5:21-cv-02777-EJD
`
`AMENDED [PROPOSED] ORDER
`GRANTING UNOPPOSED MOTION
`FOR PRETRIAL CONSOLIDATION
`AND APPOINTMENT OF INTERIM
`LEAD COUNSEL AND PLAINTIFFS’
`EXECUTIVE COMMITTEE [DKT. 28]
`
`
`Judge: Hon. Edward J. Davila
`
`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
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`2
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 3 of 12
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`WHEREAS, the Court has received and considered the motion to consolidate for pretrial
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`purposes the social casino cases against Defendants and appoint interim lead counsel and an
`executive committee submitted by various counsel for the Plaintiffs;
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`WHEREAS, the Court recognizes the need to appoint an interim lead counsel structure to
`coordinate litigation efficiently on behalf of all class members, and the importance of keeping
`time, expense reports, reasonable fees, and eliminating duplication of efforts;
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`Having reviewed all the submissions, the Court hereby finds as follows:
`I. CONSOLIDATION
`The district court may consolidate actions involving common questions of law and fact.
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`Fed. R. Civ. P. 42(a)(2). In exercising the broad discretion to order consolidation, the court “weighs
`the saving of time and effort [that] consolidation would produce against any inconvenience, delay,
`or expense that it would cause.” Huene v. United States, 743 F.2d 703, 704 (9th Cir. 1984).
`Consolidation may occur upon motion by a party or sua sponte. See 9A CHARLES ALAN WRIGHT
`ET AL., FEDERAL PRACTICE AND PROCEDURE § 2383 (3d ed. 2018).
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`The Court finds that within each set of actions—i.e., the Facebook Actions, the Google
`Actions, and the Apple Actions—each case within the set presents substantially similar factual and
`legal issues to other cases within that set. There is no basis to find that consolidation of all actions
`in each particular set would cause inconvenience, delay, or expense, especially where all plaintiffs
`agree with the consolidation request. Accordingly, some consolidation is appropriate, and the
`motions to consolidate the actions for pretrial purposes pursuant to Rule 42(a)(2) are GRANTED
`to the extent that (i) the Facebook Actions are consolidated with each other, (ii) the Apple Actions
`are consolidated with each other, and (iii) the Google Actions are consolidated with each other.
`For the avoidance of doubt, no actions against one defendant are consolidated with any actions
`against another defendant.
`
`//
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 4 of 12
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`II. APPOINTMENT OF INTERIM LEAD COUNSEL
`This Order is intended to create a leadership structure for Plaintiffs’ counsel in order to
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`organize, simplify, and streamline the handling of these matters on behalf of all Plaintiffs,
`consistent with the fair administration of justice. Plaintiffs’ counsel’s proposal strives to eliminate
`duplication by assigning discrete tasks to the Executive Committee. The Court will also actively
`monitor the work of the Interim Lead Counsel and Executive Committee by holding regular case
`management conferences to inquire into all pending and completed tasks of members of the
`leadership group.
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`The Court further believes that this structure respects the notion of starting with a small
`team and growing as needed. The proposed number of attorneys is warranted in light of the
`projected size of the case, including the potential number of class members. Efficiency will be
`promoted by putting the entire team in place and defining each member’s role at the outset of the
`case. Moreover, this structure includes a diversity of viewpoints (including in terms of gender,
`ethnicity, geographic diversity, and years of overall experience) that could prove instrumental in
`effectuating the best outcome for the Plaintiffs. Mr. Balabanian has demonstrated an ability to
`cooperate with a range of different interests that span across law firms, practice groups, geography,
`and gender and introduces smaller firms into the litigation experience. His pledge to communicate
`transparently and devise a cohesive working group is admirable and will prove a valuable resource
`in the course of the litigation.
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`Given Mr. Balabanian’s assurances that the proposed structure is designed to secure an
`efficient and beneficial result for the Plaintiffs, the Court approves the proposed Interim Lead
`Counsel and Executive Committee structure. The Court notes that some of the proposed positions
`(such as Settlement Counsel) are forward-thinking but may not require immediate implementation.
`As described, the Court encourages Interim Lead Counsel and the Executive Committee to remain
`committed to efficiency. The Court reserves the right to modify the structure at any time.
`A. Lead Counsel
`The Court has considered the chief criteria that interim lead Plaintiffs’ counsel should
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
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`4
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 5 of 12
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`possess: (1) performance of work in identifying and investigating potential claims in this action;
`(2) knowledge and experience in handling complex litigation, including class actions; (3)
`knowledge of the applicable law; and (4) access to sufficient resources to prosecute the litigation
`in a timely manner. Fed. R. Civ. P. 23(g)(1)(A), (3). The Court has also considered counsel’s
`willingness and ability to commit to a time-consuming process and to work cooperatively with
`others. See Fed. R. Civ. P. 23(g)(1)(B). Based on these factors, the Court hereby APPOINTS Rafey
`Balabanian of Edelson PC as Interim Lead Counsel in this action. The Court finds that Mr.
`Balabanian and his firm have extensive knowledge of and experience in prosecuting complex
`litigation and class actions, are both willing and able to commit to a time-consuming process of
`litigating this case, have shown the ability to work cooperatively with others by garnering the
`support of a great number of colleagues and fellow counsel in this MDL, and have access to
`sufficient resources to prosecute this litigation in a timely manner.
`B. Plaintiffs’ Executive Committee
`Having reviewed motions and supporting materials, and finding that the proposed positions
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`will advance judicial interests of efficiency and protect the interests of the proposed Classes, the
`Court hereby appoints the following individuals to the Plaintiffs’ Executive Committee:
`Head of Google Track
`John Norris [Davis & Norris]
`Head of Apple Track
`Melissa Weiner [Pearson, Simon & Warshaw, LLP]
`Head of Facebook Track
`Sarah N. Westcot [Bursor & Fisher]
`Law and Briefing Counsel
`Todd Logan [Edelson PC]
`Defensive Discovery Counsel
`Jill Manning [Steyer Lowenthal]
`Offensive Discovery and ESI Counsel
`Cecily Shiel [Tousley Brain and Stephens]
`Google Discovery Counsel
`Theo Benjamin [Edelson PC]
`Apple Discovery Counsel
`Glenn Chappell [Tycko & Zavareei]
`Facebook Discovery Counsel
`Kristen Cardoso [Kopelowitz Ostrow P.A.]
`App Maker Discovery and Claims
`Christin Cho [Dovel & Luner]
`Counsel
`Plaintiffs Vetting and Pleading Counsel Hassan A. Zavareei [Tycko & Zavareei LLP]
`Settlement Counsel
`Jay Edelson [Edelson PC]
`These appointments will last for the duration of the MDL proceeding, unless changed by
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`Interim Lead Counsel or ordered by the Court. This Court looks to these counsel to undertake
`personal responsibility to perform the designated functions and reserves the discretion to replace
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
`
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`5
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 6 of 12
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`them, on their own request or on this Court’s own motion, should they become unable to do so.
`The responsibilities of each member of the Executive Committee are detailed below.
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`III. COMPOSITION AND RESPONSIBILITIES OF INTERIM LEAD COUNSEL AND
`PLAINTIFFS’ EXECUTIVE COMMITTEE
`A. Responsibilities of Interim Lead Counsel
`The Court hereby appoints Rafey S. Balabanian as Interim Lead Counsel. With an
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`opportunity for input from the Chair, Plaintiffs’ Interim Lead Counsel shall be responsible for
`determining the litigation strategy on behalf of all Plaintiffs, and for the conduct of the litigation
`on behalf of the Plaintiff Classes, including any trial or resolution. Plaintiffs’ Interim Lead Counsel
`will attempt to reach consensus regarding major decisions with the Chair. To the extent that
`disagreements arise as to the direction of the case, and the Interim Lead Counsel and the Chair
`cannot reach a consensus, Plaintiffs’ Interim Lead Counsel shall have the final decision-making
`authority. Plaintiffs’ Interim Lead Counsel shall promote the orderly and efficient conduct of this
`litigation and avoid unnecessary duplication and unproductive efforts; act as spokesperson (either
`personally or by designee) for the Plaintiff Classes at pretrial conferences; and delegate work
`responsibilities to the Plaintiffs’ Executive Committee or its Chair.
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`Plaintiffs’ Interim Lead Counsel shall have authority to enter into stipulations (either
`personally or by designee) necessary for the conduct of the litigation with opposing counsel. No
`request for discovery, or other pretrial or trial proceedings shall be initiated or filed, and no
`dispositive motion or response to any dispositive motion shall be filed by any plaintiff, except
`through Plaintiffs’ Interim Lead Counsel.
`B. Executive Committee Chair
`The Court hereby appoints Andrea Gold of Tycko & Zavareei LLP as the Chair of the
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`Plaintiffs’ Executive Committee (the “Chair”) with the following duties:
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
`
`
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`6
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 7 of 12
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`a. The Chair shall confer with Plaintiffs’ Interim Lead Counsel regarding litigation
`strategy on behalf of all Plaintiffs, and regarding the conduct of all litigation
`efforts on behalf of the Plaintiff classes, including any trial or resolution.
`b. Following consultation with Interim Lead Counsel, the Chair shall delegate work
`responsibilities to other Plaintiffs’ counsel in a fair and orderly manner. The Chair
`shall also monitor the activities of all Plaintiffs’ counsel to assure that Plaintiffs’
`pretrial preparation is conducted effectively, efficiently, and economically; that
`schedules are met; and that unnecessary expenditures of time and expense are
`avoided.
`c. The Chair shall be available and responsible for communications to and from this
`Court, including distributing orders and other directions from the Court to counsel,
`and for providing the local rules, standing orders, and guidelines of the U.S. District
`Court for the Northern District of California, and any other judge’s rules and
`standing orders of the Court, to counsel as required by applicable Court rules.
`d. The Chair shall be responsible for creating and maintaining a master service list of
`all parties and their respective counsel, and shall promptly advise the Court and
`Defendants’ counsel of changes to Plaintiffs’ Service List.
`e. The Chair shall be responsible for ensuring that any updates and changes to the
`local rules, standing orders, and guidelines of this District or the Court are timely
`communicated to counsel as needed, working with the Executive Committee
`member(s) where it is appropriate and relevant to their responsibilities.
`f. The Chair shall be responsible for distributing to counsel, as appropriate, Orders,
`notices, and correspondence from the Court, to the extent such documents are not
`electronically filed; and discovery, pleadings, correspondence, and other
`documents from Defendants’ counsel that are not electronically filed.
`g. The Chair shall be responsible for obtaining and maintaining time records for
`Plaintiffs’ counsel, as well as preparing and submitting reports to the Court as
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`

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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 8 of 12
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`requested.
`C. Head of the Google Track
`The Court hereby appoints John Norris of Davis & Norris as Head of the Google Track.
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`The Head of the Google Track shall be responsible for coordinating and, consistent with direction
`from Interim Lead Counsel, overseeing all litigation efforts related to claims against Google,
`including pleadings, offensive and defensive fact discovery, expert discovery, and motion practice.
`The Head of the Google Track shall be primarily responsible for day-to-day communications with
`counsel for Google and, in conjunction with Interim Lead Counsel and the Chair, for ensuring that
`the Executive Committee remains apprised of all relevant information provided by Google and
`Google’s counsel.
`D. Head of the Apple Track
`The Court herby appoints Melissa Weiner of Pearson, Simon & Warshaw, LLP as Head of
`the Apple Track. The Head of the Apple Track shall be responsible for coordinating and, consistent
`with direction from Interim Lead Counsel, overseeing all litigation efforts related to claims against
`Apple, including pleadings, offensive and defensive fact discovery, expert discovery, and motion
`practice. The Head of the Apple Track shall be primarily responsible for day-to-day
`communications with counsel for Apple and, in conjunction with Interim Lead Counsel and the
`Chair, for ensuring that the Executive Committee remains apprised of all relevant information
`provided by Apple and Apple’s counsel.
`E. Head of the Facebook Track
`The Court herby appoints Sarah N. Westcot of Bursor & Fisher as Head of the Facebook
`Track. The Head of Facebook Track shall be responsible for coordinating and, consistent with
`direction from Interim Lead Counsel, overseeing all litigation efforts related to claims against
`Facebook, including pleadings, offensive and defensive fact discovery, expert discovery, and
`motion practice. The Head of Facebook Track shall be primarily responsible for day-to-day
`communications with counsel for Facebook and, in conjunction with Interim Lead Counsel and
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
`
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`8
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`
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`

`

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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 9 of 12
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`the Chair, for ensuring that the Executive Committee remains apprised of all relevant information
`provided by Facebook and Facebook’s counsel.
`F. Law and Briefing Counsel
`The Court hereby appoints Todd Logan of Edelson PC as Law and Briefing Counsel. The
`Law and Briefing Counsel will be responsible for coordinating the research and preparation of all
`pleadings and motions and assisting in the preparation of oral arguments at any hearings. Law and
`Briefing Counsel will consider input from all Track chairs in the prosecution of these
`responsibilities.
`G. Defensive Discovery Counsel
`The Court hereby appoints Jill Manning of Steyer Lowenthal as Defensive Discovery
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`Counsel. Defensive Discovery Counsel shall be responsible for coordinating all discovery
`obligations of Plaintiffs and the Classes consistent with the requirements of the Federal Rules of
`Civil Procedure, including the preservation of information, Rule 26 initial disclosures, responses
`to interrogatories, requests for production of documents, and request for admissions, and
`examination at depositions, as well as any motion practice related thereto. Defensive Discovery
`Counsel will consider input from all Track chairs in the prosecution of these responsibilities.
`H. Offensive Discovery and ESI Counsel
`The Court hereby appoints Cecily Shiel of Tousley Brain and Stephens as Offensive
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`Discovery and ESI Counsel. Offensive Discovery and ESI Counsel shall be responsible for
`coordinating all discovery propounded on behalf of the Plaintiffs and the Classes consistent with
`the requirements of the Federal Rules of Civil Procedure, including the pursuit of information,
`Rule 26 initial disclosure negotiation, interrogatories, requests for production of documents,
`requests for admissions, depositions, and any motion practice related thereto. Offensive Discovery
`and ESI Counsel shall also be responsible for coordinating ESI practices in this case, including
`negotiations with Defendants concerning an e-discovery plan, developing an ESI protocol for this
`case, and ensuring that appropriate protective orders are in place to guard against any release of
`proprietary, confidential, or personal ESI. Offensive Discovery and ESI Counsel will assess ESI
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`

`

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`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 10 of 12
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`needs and issues, implement appropriate ESI preservation procedures, identify custodians of
`potentially relevant ESI, and develop search terms for data searches. Offensive Discovery and ESI
`Counsel will also handle ESI processing tasks and shall ensure that responsive ESI is collected and
`produced in a cost-effective manner that preserves the integrity of that ESI and enables counsel to
`recognize and appropriately deal with evidentiary issues associated with the admissibility of
`electronically generated and stored evidence. Offensive Discovery and ESI Counsel will consider
`input from all Track chairs in the prosecution of these responsibilities.
`I. Google Discovery Counsel
`The Court hereby appoints Theo Benjamin of Edelson PC as Google Discovery Counsel.
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`Google Discovery Counsel shall be responsible, together with Offensive Discovery and ESI
`Coordination Counsel, for coordinating discovery efforts related to all claims against Google.
`Google Discovery Counsel will inform and educate Offensive Discovery and ESI Counsel about
`the relevant legal and factual issues affecting discovery, including witnesses, key evidentiary
`issues, and any relevant risks associated with the discovery tasks at hand, and will work with the
`Interim Lead Counsel to select, retain, and consult with appropriate experts concerning device
`development issues.
`J. Apple Discovery Counsel
`The Court hereby appoints Glenn Chappell of Tycko & Zavareei as Apple Discovery
`Counsel. Apple Discovery Counsel shall be responsible, together with Offensive Discovery and
`ESI Coordination Counsel, for coordinating discovery efforts related to all claims against Apple.
`Apple Discovery Counsel will inform and educate Offensive Discovery and ESI Counsel about
`the relevant legal and factual issues affecting discovery, including witnesses, key evidentiary
`issues, and any relevant risks associated with the discovery tasks at hand, and will work with the
`Interim Lead Counsel to select, retain, and consult with appropriate experts concerning device
`development issues.
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`
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`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
`
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`10
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`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
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`
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`

`

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`
`K. Facebook Discovery Counsel
`The Court hereby appoints Kristen Cardoso of Kopelowitz Ostrow P.A as Facebook
`Discovery Counsel. Facebook Discovery Counsel shall be responsible, together with Offensive
`Discovery and ESI Coordination Counsel, for coordinating discovery efforts related to all claims
`against Facebook. Facebook Discovery Counsel will inform and educate Offensive Discovery and
`ESI Counsel about the relevant legal and factual issues affecting discovery, including witnesses,
`key evidentiary issues, and any relevant risks associated with the discovery tasks at hand, and will
`work with the Interim Lead Counsel to select, retain, and consult with appropriate experts
`concerning device development issues.
`L. App Maker Discovery and Claims Counsel
`The Court hereby appoints Christin Cho of Dovel & Luner as App Maker Discovery and
`Claims Counsel. App Maker Discovery and Claims Counsel shall be responsible for coordinating
`all third-party discovery propounded on behalf of the Plaintiffs and the Classes, consistent with
`the requirements of the Federal Rules of Civil Procedure and applicable local rules, including the
`pursuit of documents, depositions, and any motion practice related to third-party discovery. App
`Maker Discovery and Claims Counsel will coordinate third-party discovery with Offensive
`Discovery and ESI Counsel and Interim Lead Counsel to evaluate and develop procedures and a
`plan for discovery of third parties that is efficient, cost-effective, and non-duplicative.
`Additionally, App Maker Discovery and Claims Counsel shall coordinate with Interim Lead
`Counsel to determine whether and when to pursue certain actions directly against social casino
`app makers, potentially including actions in state and federal courts as well as claims in arbitral
`fora.
`
`M. Plaintiffs Vetting and Pleading Counsel
`The Court hereby appoints Hassan A. Zavareei of Tycko & Zavareei LLP as Plaintiffs
`Vetting and Pleading Counsel. Plaintiffs Vetting and Pleadings Counsel shall be responsible for
`coordinating all vetting of Plaintiffs as part of the development of consolidated amended pleadings,
`on behalf of Plaintiffs and the Classes. Plaintiffs Vetting and Pleadings Counsel will coordinate
`
`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
`
`
`
`11
`
`
`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
`
`
`
`

`

`Case 5:21-cv-02777-EJD Document 77 Filed 09/23/21 Page 12 of 12
`
`with Law and Briefing Counsel and Interim Lead Counsel in connection with the vetting process
`and the preparation of the pleadings related thereto.
`N. Settlement Counsel
`The Court hereby appoints Jay Edelson of Edelson PC as Settlement Counsel. Settlement
`Counsel shall be responsible for coordinating efforts relating to relief, including both monetary
`and injunctive relief. Settlement Counsel’s responsibilities shall include coordinating all
`settlement-related issues raised in discovery, expert disclosures, motions or trial, as well as
`assisting Interim Lead Counsel in representing the Plaintiff Classes in any arbitrations, mediations,
`and/or settlement conferences, consistent with the Court’s ADR Local Rules and procedures.
`
`IT IS SO ORDERED.
`
`Dated:
`
`September 23, 2021
`
`EDWARD J. DAVILA
`UNITED STATES DISTRICT JUDGE
`
`AMENDED [PROPOSED] ORDER GRANTING MOTION TO
`APPOINT INTERIM LEAD COUNSEL AND PEC
`CASE NOS. 21-MD-2985-EJD, 21-MD-3001-EJD,
`21-CV-2777-EJD
`
`12
`
`
`EDELSON PC
`150 California Street, 18th Floor
`San Francisco, CA 94111
`Tel: 415.212.9300 • Fax: 415.373.9435
`
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