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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
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`Case No.: 7:20-cv-03032-CS
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`
`Lauren Biegel, Greg Maroney, Ryan
`Cosgrove, Clive Rhoden, Stephen Bradshaw,
`Angela Farve and Christina Henderson,
`individually and on behalf of all others
`similarly situated,
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`Plaintiffs,
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`v.
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`Blue Diamond Growers,
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`Defendant.
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`
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`PLAINTIFFS’ UNOPPOSED NOTICE OF MOTION AND MOTION FOR
`PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, PRELIMINARY
`CERTIFICATION OF SETTLEMENT CLASS, AND APPROVAL OF NOTICE PLAN
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`
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`Case 7:20-cv-03032-CS Document 47 Filed 04/19/21 Page 2 of 3
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`Plaintiffs1 Lauren Biegel (“Biegel”), Greg Maroney (“Maroney”), Stephen Bradshaw
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`(“Bradshaw”), Angela Farve (“Farve”), Ryan Cosgrove (“Cosgrove”), Clive Rhoden (“Rhoden”),
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`and Christina Henderson (“Henderson”) (collectively, the “Plaintiffs”), on behalf of themselves
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`and on behalf of those similarly situated, hereinafter the Settlement Class Members, respectfully
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`move this Court for an Order preliminarily approving the proposed class action settlement filed
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`concurrently with this motion on April 19, 2021 (“Settlement”), approving the form of notice, and
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`scheduling the final approval hearing as set forth in the Settlement Agreement attached as Exhibit
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`1 to the Declaration of Spencer Sheehan filed concurrently on April 19, 2021 (“Sheehan
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`Declaration” or “Sheehan Decl.”). Specifically, the Parties ask that the Court enter the proposed
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`Order, thereby:
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`certifying the Settlement Class and appointing Plaintiffs as the class representatives
`and their counsel as Class Counsel;
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`preliminarily approving the Settlement Agreement;
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`approving the form and manner of the class action settlement notice;
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`preliminarily certifying the Settlement Class for purposes of settlement only;
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`appointing Angeion Group as Settlement Administrator and direct it to commence
`the Notice Plan; and
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`scheduling a Final Approval Fairness Hearing to consider final approval of the
`Settlement.
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`In support of this Unopposed Motion, Plaintiffs rely on the attached Memorandum of Law, as well
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`as the Declaration of Spencer Sheehan, and the Declaration of Steven Weisbrot, and their
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`supporting exhibits, all documents filed therewith.
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`1 Unless otherwise indicated, capitalized terms shall have the same meaning as they do in the
`Settlement Agreement.
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`1
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`Case 7:20-cv-03032-CS Document 47 Filed 04/19/21 Page 3 of 3
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`Respectfully submitted on this 19th day of April, 2021.
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`SHEEHAN & ASSOCIATES, P.C.
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`By: /s/ Spencer Sheehan
`Spencer Sheehan
`505 Northern Blvd., Suite 311
`Great Neck, New York 11021
`Telephone: (516) 303-0552
`Facsimile: (516) 234-7800
`spencer@spencersheehan.com
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`SHUB LAW FIRM LLC
`Kevin Laukaitis
`134 Kings Hwy. E., 2nd Floor
`Haddonfield, NJ 08033
`Tel: (856) 772-7200
`Fax: (856) 210-9088
`klaukaitis@shublawyers.com
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`REESE LLP
`Michael R. Reese
`100 West 93rd Street, 16th Floor
`New York, New York 10025
`Telephone: (212) 643-0500
`Facsimile: (212) 253-4272
`mreese@reesellp.com
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` Counsel for Plaintiffs and the Proposed Class
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`2
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