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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF PENNSYLVANIA
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`Case No.: 2:20-cv-06350-CFK
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`ROBYN LIPETZ and SHANNON
`KEENER, on behalf of themselves and all
`others similarly situated,
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`Plaintiffs,
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`v.
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`UNILEVER UNITED STATES, INC., and
`CONOPCO, INC. d/b/a UNILEVER
`HOME & PERSONAL CARE USA,
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`Defendants.
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`CONSENT ORDER TRANSFERRING ACTION
`TO THE NORTHERN DISTRICT OF ILLINOIS
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`THIS MATTER having been presented to the Court through the undersigned counsel
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`upon the consent of Plaintiffs Robyn Lipetz and Shannon Keener (collectively, “Plaintiffs”) and
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`Defendants Unilever United States, Inc. and Conopco, Inc. d/b/a Unilever Home & Personal
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`Care USA (collectively, “Defendants,” and together with Plaintiffs, the “Parties”):
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`WHEREAS, Plaintiffs filed the above-captioned action (this “Action”) on December 17,
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`2020;
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`WHEREAS, substantially similar actions have been filed in other jurisdictions,
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`specifically: (i) Castillo v. Unilever United States, Inc., et al., No. 1:20-cv-06786, filed on
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`November 16, 2020, in the United States District Court for the Northern District of Illinois (the
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`“First-Filed Action”); (ii) Libbey v. Unilever United States, Inc., et al., No. 4:20-cv-08075-JSW,
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`filed on November 16, 2020, in the United States District Court for the Northern District of
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`California; and (iii) Arroyo v. Unilever United States, Inc., et al., No. 2:21-cv-00302, filed on
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`{00197056 }
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`January 7, 2021, in the United States District Court for the District of New Jersey (collectively,
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`the “Related Actions”);
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`WHEREAS, the Plaintiffs in this Action and the plaintiffs in the Related Actions are
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`represented by overlapping counsel;
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`WHEREAS, this Action and the Related Actions involve the same Defendants and are
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`asserted on behalf of nationwide putative classes of purchasers of the same products
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`manufactured by Defendant Unilever United States, Inc.;
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`WHEREAS, this Action and the Related Actions involve substantially similar issues of
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`fact and law;
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`WHEREAS, litigating this Action and the Related Actions in separate jurisdictions would
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`be inefficient and present the risk of inconsistent results, and would be inconvenient to the
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`Parties and witnesses alike;
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`WHEREAS, having this Action and the Related Actions proceed before the same Court
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`will eliminate the potential for inconsistent rulings on critical pretrial motions, including class
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`certification, eliminate the burden of duplicative discovery on common issues, prevent
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`unnecessary use of judicial resources, and reduce the overall costs and burdens for all parties;
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`WHEREAS, the Parties jointly seek to transfer this Action to the United States District
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`Court for the Northern District of Illinois, the jurisdiction in which the First-Filed Action was
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`filed, which would serve the convenience of the Parties and witnesses, and the interests of
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`justice, as contemplated by 28 U.S.C. § 1404(a);
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`WHEREAS, the parties to the Related Actions have agreed to consolidation in the
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`Northern District of Illinois, where Plaintiffs have agreed to file a consolidated amended
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`complaint to supersede the Complaint in this Action and the Complaints in the Related Actions,
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`2
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`and to avoid burdening the Court, and the Parties have further agreed to adjourn Defendants’
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`need to answer or move with respect to the current complaints until such time as Plaintiffs file
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`that consolidated amended complaint, and filed a motion in the Castillo Action pending in the
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`Northern District of Illinois to this effect on February 17, 2021 [Dkt. No. 17]; and
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`WHEREAS, the parties to the remaining Related Actions have sought, or will soon seek,
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`to transfer such actions to the Northern District of Illinois.
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`IT IS on this 5th_day of _March 2021, hereby:
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`ORDERED, upon good cause shown, that this Action is transferred to the Northern
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`District of Illinois pursuant to 28 U.S.C. § 1404; and
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`ORDERED that the stay provided under Local Civil Rule 3.2 shall not apply to this
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`Order.
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`SO ORDERED: ______/s/ Chad F. Kenney______________ DATE: March 5, 2021
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`Hon. Chad F. Kenney, U.S.D.J.
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`We hereby consent to the form and entry of the within Order.
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`Dated: February 19, 2021
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`s/ Jonathan Shub
`Jonathan Shub (SBN 53965)
`Kevin Laukaitis
`SHUB LAW FIRM LLC
`134 Kings Highway E, 2nd Floor
`Haddonfield, NJ 08033
`T: 856-772-7200
`F: 856-210-9088
`jshub@shublawyers.com
`klaukaitis@shublawyers.com
`
`Melissa R. Emert
`Gary S. Graifman
`KANTROWITZ, GOLDHAMER &
`GRAIFMAN, P.C.
`747 Chestnut Ridge Road
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`3
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`February 19, 2021
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`Chestnut Ridge, New York 10977
`T: 845-356-257
`F: 845-356-4335
`memert@kgglaw.com
`ggraifman@kgglaw.com
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`Attorneys for Plaintiffs
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`s/ Michael Kaplan
`Michael Kaplan (SBN 323507)
`LOWENSTEIN SANDLER LLP
`1 Lowenstein Drive
`Roseland, NJ 07068
`T: 973-597-2500
`F: 973-597-2400
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`Attorneys for Defendants
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`4
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