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`SCOTT GILMORE, et al.,
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`Plaintiffs,
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`MONSANTO COMPANY,
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`Defendant.
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`v.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 20-1085-MN
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`PLAINTIFFS’ MOTION FOR PRELIMINARY APPROVAL OF
`CLASS ACTION SETTLEMENT AND FOR CERTIFICATION OF
`THE CLASS FOR THE PURPOSES OF SETTLEMENT
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`Pursuant to Federal Rule of Civil Procedure 23, Plaintiffs Scott Gilmore, Julio Ezcurra,
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`James Weeks, Amanda Boyette, Anthony Jewell, Paul Taylor, Sherry Hanna, and Kristy Williams
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`(“Plaintiffs”), on behalf of themselves and the Settlement Class, and with Defendant Monsanto
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`Company’s consent, hereby move for (1) preliminary approval of the proposed Class Action
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`Settlement Agreement attached as Exhibit 1 to the declaration of Gillian Wade filed concurrently
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`herewith; (2) preliminary certification of the proposed Settlement Class for purposes of settlement
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`and appointment of the Plaintiffs and their counsel as Class Representatives and Class Counsel,
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`respectively; (3) approval of the Class Notice and Notice Plan; and (4) setting of a fairness hearing
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`and other necessary dates in connection with Final Approval of the Class Action Settlement
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`Agreement.
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`The grounds and support for this motion are set forth in more detail in Plaintiffs’ supporting
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`memorandum and the accompanying declarations and exhibits filed concurrently herewith.
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`Case 1:20-cv-01085-MN Document 24 Filed 06/14/21 Page 2 of 2 PageID #: 2310
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`Dated: June 14, 2021
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`/s/ Chandra J. Williams
`William J. Rhodunda, Jr. (#2774)
`Chandra J. Williams (#4907)
`Rhodunda Williams & Kondraschow
`Brandywine Plaza West
`1521 Concord Pike, Suite 205
`Wilmington, DE 19803
`Bill@rawlaw.com
`Chandra@rawlaw.com
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`Gillian L. Wade (admitted pro hac vice)
`Marc A. Castaneda (admitted pro hac vice)
`Sara D. Avila (admitted pro hac vice)
`MILSTEIN, JACKSON,
`FAIRCHILD & WADE, LLP
`10250 Constellation Blvd., Suite 1400
`Los Angeles, CA 90067
`Telephone: (310) 396-9600
`Fax: (310) 396-9635
`gwade@mjfwlaw.com
`mcastaneda@mjfwlaw.com
`savila@mjfwlaw.com
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`Counsel for Plaintiffs
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`2
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