`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`IN RE ZYNERBA PHARMACEUTICALS,
`INC. DERIVATIVE LITIGATION
`
`
`C.A. No. 20-cv-557-CFC
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`
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`PLAINTIFFS’ UNOPPOSED MOTION FOR
`PRELIMINARY APPROVAL OF SETTLEMENT
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`Plaintiffs Phillip Quartararo and Dmitry Itkis (“Derivative Plaintiffs”) hereby
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`move this Court, pursuant to Rule 23.1 of the Federal Rules of Civil Procedure, for
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`entry of an order: (1) granting preliminary approval of the proposed Settlement as
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`set forth in the Stipulation and Agreement of Settlement dated April 28, 2021 (the
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`“Stipulation”)1; (2) approving the Parties’ proposed method and manner of providing
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`notice of the Settlement to Zynerba Pharmaceuticals, Inc. stockholders; (3)
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`scheduling a hearing at which time the Court will consider whether the proposed
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`Settlement should be granted final approval; and (4) granting such other relief as the
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`Court deems just and proper.
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`In support of this motion, Derivative Plaintiffs rely
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`upon the accompanying Brief in Support, the Declaration of Brian E. Farnan in
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`Support of Plaintiffs’ Unopposed Motion for Preliminary Approval of Settlement
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`(the “Declartion”), the Stipulation and exhibits annexed thereto, and all prior
`
`
`1 Unless otherwise defined herein, all defined terms shall have the meanings as set
`forth in the Stipulation, which is attached as Exhibit 1 to the Declaration of Brian E.
`Farnan in Support of Plaintiffs’ Unopposed Motion for Preliminary Approval of
`Settlement.
`
`1
`
`
`
`Case 1:20-cv-00557-CFC Document 28 Filed 05/07/21 Page 2 of 2 PageID #: 409
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`pleadings and proceedings.
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`The Parties’ agreed-upon form of proposed Preliminary Approval Order is
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`attached as Exhibit C to the Stipulation attached to the Declaration. Derivative
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`Plaintiffs respectfully request that the Court enter the proposed Preliminary
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`Approval Order and insert a date for the final settlement hearing in paragraph 2.
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`
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`Defendants do not oppose this motion.
`
`
`
`
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`Respectfully submitted,
`
`FARNAN LLP
`
` /s/ Brian E. Farnan
`Brian E. Farnan (#4089)
`Michael J. Farnan (#5165)
`919 N. Market St., 12th Floor
`Wilmington, DE 19801
`Telephone: (302) 777-0300
`
`DELEEUW LAW LLC
`
` /s/ P. Bradford deLeeuw
`P. Bradford deLeeuw (#3569)
`1301 Walnut Green Road
`Wilmington, DE 19807
`Telephone: (302) 274-2180
`
`Co-Liaison Counsel for Plaintiff
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`
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`
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`Dated: May 7, 2021
`
`Of Counsel:
`
`Garam Choe
`BRAGAR EAGEL & SQUIRE, P.C.
`810 Seventh Avenue, Suite 620
`New York, NY 10019
`Telephone: (212) 355-4648
`
`Timothy Brown
`THE BROWN LAW FIRM, P.C.
`240 Townsend Square
`Oyster Bay, NY 11771
`Telephone: (516) 922-5427
`
`Co-Lead Counsel for Plaintiffs
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`2
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