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1 Douglas J. Campion (SBN 1 doug@djcampion.com THE LAW OFFICE OF DOUGLAS J. CAMPION, APC 0 Via Del Campo, Suite 0 San Diego, CA 1 Telephone: ( -01 James O. Latturner (Pro Hac Vice info@edcombs.com EDELMAN COMBS LATTURNER & GOODWIN, LLC 0 South Clark Street, Suite 0 Chicago, IL 00 Telephone: (1-00 [Additional Counsel Listed on Last Page] Co-Lead Counsel for Plaintiffs UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA IN RE: MIDLAND CREDIT MANAGEMENT, INC., TELEPHONE CONSUMER PROTECTION ACT LITIGATION / / / / / / Case No. -md--mma (MDD Member cases: -cv-01 -cv-000 -cv-0 -cv-00 CLASS ACTION PLAINTIFFS MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF UNOPPOSED MOTION FOR ATTORNEYS FEES AND APPROVAL OF COSTS, AND FOR INCENTIVE PAYMENTS Date: August, 01 Time: :00 a.m. Courtroom: A Judge Michael M. Anello -md--mma (MDD

2 TABLE OF CONTENTS I. INTRODUCTION...1 II. III. IV. STATEMENT OF FACTS A. FACTUAL AND PROCEDURAL BACKGROUND... B. PROCEEDINGS TO DATE... THE SETTLEMENT..... A. SUMMARY OF SETTLEMENT B. CLASS REPRESENTATIVES INCENTIVE AWARDS..... C. ATTORNEYS FEES AND LITIGATION EXPENSES... D. CY PRES DISTRIBUTION THE ATTORNEYS FEES SOUGHT ARE REASONABLE AND SHOULD BE AWARDED BY THE COURT... A. THE ATTORNEYS FEES ARE JUSTIFIED IF THE METHOD USED IS BASED ON A PERCENTAGE OF THE VALUE OF THE SETTLEMENT.. 1. THE COURT CAN VIEW THE TOTALITY OF THE SETTLEMENT S VALUE AS A COMMON FUND AND AWARD A PERCENTAGE OF THAT VALUE.. APPLYING THE VIZCAINO FACTORS, COUNSEL ARE ENTITLED TO A PERCENTAGE OF THE VALUE OF THE TOTAL SETTLEMENT a. b. CLASS COUNSEL ACHIEVED EXCEPTIONAL RESULTS FOR THE CLASS.... THE CONTINGENT NATURE OF THIS CASE AND THE RISK TAKEN i- -md--mma (MDD

3 c. d. e. f. THE NOVELTY AND DIFFICULTY OF QUESTIONS INVOLVED... THE EXPERIENCE, REPUTATION AND ABILITY OF COUNSEL (1 THE LAW OFFICES OF DOUGLAS J. CAMPION, APC. ( EDELMAN, COMBS, LATTURNER & GOODWIN, LLC..... ( LAW OFFICES OF DAVID SCHAFER, PLLC ( KAZEROUNI LAW GROUP, APC.... ( HYDE & SWIGART.... ( WARNER LAW FIRM, LLC THE RISK OF NON-PAYMENT AND THE DELAY IN PAYMENT....1 AWARDS MADE IN SIMILAR CASES 1. IN ADDITION, MANY MORE HOURS WILL BE INCURRED BEFORE THE FINAL APPROVAL HEARING AND BEYOND, FURTHER JUSTIFYING THE FEE REQUEST....1 B. IF THE LODESTAR ANALYSIS IS USED, THE ATTORNEYS FEES SOUGHT RESULT IN A MULTIPLIER OF 1.1, JUSTIFIED BY KERR AND VIZCAINO FACTORS COUNSEL S HOURLY RATES ARE REASONABLE AND ARE CONSISTENT WITH MARKET RATES THE NUMBER OF HOURS SUBMITTED BY COUNSEL IS REASONABLE A MULTIPLIER IS APPROPRIATE IN THIS CASE... (a. (b. THE KERR FACTORS ARE SATISFIED.... THE MULTIPLIER IS WITHIN THE RANGE OF REASONABLENESS ii- -md--mma (MDD

4 V. THE PAYMENT OF COSTS IS FAIR AND REASONABLE VI. THE CLASS RESPONSE TO DATE SUPPORTS APPROVAL OF THE REQUESTED FEE VII. THE COURT SHOULD APPROVE A $,00 INCENTIVE AWARD... VIII. CONCLUSION iii- -md--mma (MDD

5 TABLE OF AUTHORITIES CASES Arthur et al. v. Sallie Mae Inc. (W.D. Wash Ballen v. City of Redmond F.d (th Cir Clark v. City of Los Angeles 0 F.d (th Cir.... Connor v. JPMorgan Chase (S.D. Cal Davis v. City and County of San Francisco F.d 1 (th Cir....1 Fadhl v. City and County of San Francisco F.d (th Cir.... Fitzgerald v. City of Los Angeles 00 WL 1 (C.D. Cal, Fischel v. Equitable Life Assur. Society of U.S. 0 F.d (th Cir Grays Harbor Adventist Christian School v. Carrier Corp. No. 0-0 RBL, 00 WL 0 (W.D. Wash , Gutierrez, et al. v. Barclays Group, et al. (S.D. Cal Hanlon v. Chrysler Group F.d (th Cir...., 1, Hensley v. Eckerhart 1 U.S. (...1, 1 In re Bluetooth Headset Products Liab. Litig. F.d (th Cir , 1 -iv- -md--mma (MDD

6 In re Brooktee Sec. Litig. 1 F. Supp. (S.D. Cal In re Diet Drugs F.d (d Cir In re Heritage Bond Litigation 00 WL 0 (C.D. Cal., In re Immune Response Sec. Litig. F. Supp. d (S.D. Cal , 1 In re M.D.C. Holdings Sec. Litig. CV-000 E (M, 0 WL (S.D. Cal. Aug. 0, In re Media Vision Tech. Sec. Litig. 1 F. Supp. 1 (N.D. Cal....1 In re Mecury Interactive Corp. 1 F.d (th Cir In re Merry-Go-Round Enterprises, Inc. B.R. (Bankr. D. Md In re Pac. Enters. Sec. Litig. F.d (th Cir In re Pub. Serv. Co. of New Mex. No. 1-0M, WL, * (S.D. Cal. July, In re Rite Aid Corp. Sec. Litig. F. Supp. d (E.D. Pa In re RJR Nabisco Inc. Sec. Litig. WL 1 (S.D.N.Y Aug In re Vioxx Products Liability Litig. 0 F. Supp. d 0 (E.D. La In re Wash. Pub. Power Supply Sys. Sec. Litig. F.d 1 (th Cir...., -v- -md--mma (MDD

7 Jackson v. Austin F.Supp. d (D. Kan Kerr v. Screen Extras Guild, Inc. F.d (th Cir...., 1, 1,, 0 Kramer v. Autobytel (N.D. Cal Lozano v. Twentieth Century Fox (N.D. Ill Moreno v. City of Sacramento F.d 0 (th Cir Mills v. Electric Auto-Lite Co. U.S. (0...1 Morris v. Lifescan, Inc. Fed. Appx. (th Cir Newhouse v. Robert s Ilima Tours, Inc. 0 F.d (th Cir....1 Paul, Johnson, Alston & Hunt v. Graulty F.d ( th Cir..... Pelletz v. Weyerhaeuser Co. F. Supp. d 1 (W.D. Wash , Pennsylvania v. Delaware Valley Citizens Council for Clean Air U.S. (...,,,,...1 Perkins v. Mobile Housing Board F.d (th Cir....1 Perkins v. Screen Extras Guild, Inc. U.S. 1 (... Rojas v. Career Educ. Corp. (N.D. Ill vi- -md--mma (MDD

8 Six Mexican Workers 0 F.d 1 (th Cir State of Florida v. Dunne 1 F.d (th Cir Steiner v. Am. Broad. Co. Fed Appx. 0 (th Cir Van Vranken v. Atlantic Richfield Co. 01 F. Supp. (N.D. Cal.,... Vizcaino v. Microsoft Corp. 0 F.d (th Cir Welch v. Metropolitan Life Ins. Co. 0 F.d (th Cir Wing v. Asarco, Inc. F.d (th Cir Statutes Telephone Consumer Protection Act ( TCPA, U.S.C. et...passim Treatises Manual for Complex Litigation, (th ed , at vii- -md--mma (MDD

9 I. INTRODUCTION Pursuant to the Settlement Agreement and Release ( Agreement 1 and the Order granting preliminary approval to the Settlement (ECF No. 1, Class Counsel, as counsel for Plaintiffs Christopher Robinson ( Robinson and Dave Scardina ( Scardina, and Liaison Counsel, counsel for Eduardo Tovar ( Tovar, ( Plaintiffs or Class Representatives move for an award of attorneys fees and reimbursement of litigation expenses in the amount of $. million. That amount, subject to Court approval, is to be paid by Defendants separate from and in addition to the Settlement Fund, and was negotiated and agreed upon in mediation with Judge Herbert Hoffman, (Ret. of Judicate West. This motion is unopposed by Defendants Midland Funding, LLC ( Midland Funding, Midland Credit Management, Inc. ( MCM, and Encore Capital Group, Inc. ( Encore (collectively Defendants. The Parties negotiated and agreed upon attorneys fees and costs only after negotiating and reaching an agreement on the other terms of the Settlement. Also pursuant to the Agreement, Plaintiffs counsel move for approval of incentive payments of $,00 each to be paid to the three Class Representatives, Robinson, Tovar, and Scardina for their services to the Settlement Class. The Agreement provides that Plaintiffs incentive payments will be paid from the Cash Component of the Settlement Fund. 1 Agreement previously filed as Exhibit 1 to the Declaration of Douglas J. Campion In Support of Preliminary Approval, ECF No. 1-. The firms submitting hours and costs with this motion are only those listed as counsel in the three cases of co-lead and liaison counsel. Co-Lead counsel Douglas J. Campion, APC, is co-counsel with Hyde & Swigart and the Kazerouni Law Group, APC in the Robinson case, S.D. Cal.-cv-1 MMA MDD; co-lead counsel Edelman, Combs, Latturner & Goodwin, LLC, is co-counsel with the Warner Law Firm, PLLC on the Scardina case, N.D. Ill. -cv-; and liaison counsel Law Office of David Schafer, is counsel in the Tovar case, S.D.Cal. -cv- 00 MMA MDD -1- -md--mma (MDD

10 II. STATEMENT OF FACTS A. Factual and Procedural Background. Defendants or their subsidiaries were at all relevant times, and in particular between November, 00 through August 1, 01, inclusive (the Class Period, involved or engaged in the business of purchasing debts owed, or allegedly owed by consumers, and attempting to collect them. In this suit, Plaintiffs allege that, in their efforts to collect debts from consumers, Defendants violated the Telephone Consumer Protection Act, U.S.C. et seq., ( TCPA. Plaintiffs allege they did so by calling cellular telephones without prior express consent, using an automatic telephone dialing system and/or using an artificial or prerecorded voice, and that Plaintiffs are entitled to statutory damages. Defendants have denied and continue to deny that they violated the TCPA. B. Proceedings to Date. On November, 0 and December 1, 0 respectively, Plaintiffs Robinson and Tovar filed actions against Defendants in this Court. On May, 0, Plaintiff Scardina filed an action against Defendants in the United States District Court for the Northern District of Illinois. The complaints in all three actions alleged that Defendants violated the TCPA. On October, 0, Plaintiffs actions were transferred to this Court by the Multi-District Litigation ( MDL Panel for coordinated or consolidated pretrial proceedings. (ECF No. 1. On March 1, 01, the Court appointed Interim Co- Lead Counsel and Liaison Counsel. (ECF No. 1. On July, 01, Plaintiffs filed a Consolidated Complaint (ECF No. which Defendants answered on August 1, 01. (ECF No.. On December, 01, Defendants filed a Motion to Stay on Primary Jurisdiction Grounds (ECF No. 0 which, after briefing and oral argument, the Court denied on January, 01. (ECF No.. Subsequent to that ruling, the Parties began protracted settlement discussions with the assistance of mediator Judge Hoffman of Judicate West, resulting in a settlement approximately thirty -- -md--mma (MDD

11 months later. On December, 01, the Court entered Order Granting Plaintiffs Motion for Preliminary Approval of Class Action Settlement (ECF No. 1. The Order, inter alia, (i preliminarily certified (for settlement purposes only a class ( the Settlement Class or Settlement Class Members ; (ii preliminarily approved the Agreement, (iii appointed Plaintiffs Robinson, Tovar, and Scardina as the Representatives of the Settlement Class; (iv appointed Douglas J. Campion of the Law Offices of Douglas J. Campion, APC and James O. Latturner of Edelman, Combs, Latturner & Goodwin, LLC as Class Counsel and appointed the Law Office of David Schafer, PLLC as liaison counsel; and (v set the date and time of the Final Approval Hearing for August, 01, at :00 a.m. At the time of the Final Approval Hearing, Class Counsel will seek Court approval of $. million in attorneys fees and costs by this motion. Settlement Class Members were given notice that Class Counsel would be seeking this award, subject to Court approval. To date there has been no objection filed challenging the amount sought by Class Counsel for fees and costs. By this application, and as detailed in the supporting declarations filed herewith, Plaintiffs counsel seek an award of attorneys fees and costs based upon about,0 hours of time incurred, for a lodestar to date of $1,,0.00 as detailed in a table below in Section IV.b.. III. THE SETTLEMENT A. Summary of Settlement. For the sake of brevity, Plaintiffs refer the Court to the detailed explanation of Class Counsel is also posting this motion on the Settlement Website at the time of filing. See Declarations of attorneys Douglas J. Campion, James O. Latturner, David P. Schafer, Curtis C. Warner, Joshua B. Swigart and Abbas Kazerounian In Support of Motion for Award of Attorneys Fees, Costs and Incentive Awards for Plaintiffs filed herewith ( Fee Decl. -- -md--mma (MDD

12 the settlement, the settlement class and the claims process contained in Plaintiff s Memorandum of Points & Authorities in Support of Preliminary Approval, ECF No. 1-1 at -1. To summarize, the class consists of those persons called on their cellphones by Defendants (excluding certain named subsidiaries with an automatic telephone dialing system or prerecorded voice message without prior consent from November, 00 through August 1, 01, inclusive. The settlement consists of a number of parts: 1 a Settlement Fund of $1,000,000, of which $1,000,000 is to be applied pro rata as credits to claimants accounts that are still open with Defendants, and a $,000,000 cash fund to pay the claimants on a pro rata basis that do not have an open account with Defendants. (It was estimated in settlement discussions that approximately % of the Class Members had no open account so the cash component is smaller than the credit component. Defendants will pay all costs of notice and claims administration in addition to the Settlement Fund, which at the time of Preliminary Approval was estimated to be between $,0,0 and $,,0. Defendants agreed to pay $,00,000 in attorneys fees and costs incurred by Plaintiffs counsel in litigating this matter. Thus, this settlement has a value to the Class of $0,,0, assuming the higher cost of claims administration. B. Class Representatives Incentive Awards. The Settlement contemplates payment of $,00 each to the three Class Representatives, subject to Court approval. Agreement, Defendants have agreed not to oppose a request for payment of such amounts. Id. C. Attorneys Fees And Litigation Expenses. Subject to the Court s approval, the Settlement contemplates, and Defendants agree not to oppose, an award of attorneys fees and litigation costs of up to $,00,000 to be paid separate and apart from the Settlement Fund. Agreement,.0; md--mma (MDD

13 D. Cy Pres Distribution. Any checks distributed from the Cash Component of the Settlement Fund which remain uncashed days after they are issued shall be distributed to one or more cy pres recipients chosen by Settlement Class Counsel, agreed to by Defendants, and approved by the Court. Agreement,.0,.0. IV. THE ATTORNEYS FEES SOUGHT ARE REASONABLE AND SHOULD BE AWARDED BY THE COURT. A. The Attorneys Fees Are Justified if The Method Used is Based on a Percentage of the Value of the Settlement. Plaintiffs seek Court approval of their request for an award of fees and costs of $. million. This is not a fee shifting case as the TCPA does not provide for fee shifting, and, because the total amount paid by Defendants is not paid into one common fund, Class Counsel are not seeking fees strictly on that basis. Nonetheless, even though Counsel are not seeking fees on the basis of a common fund, the reasonableness of Counsel s fee request can be evaluated as though this case were a common fund case. Where, as here, a settlement produces a common benefit for the entire class, courts have discretion to employ either the lodestar method or the percentage-ofrecovery method. In Re Bluetooth Headset Products Liab. Litig., F.d, (th Cir. 0 (citing In re Mercury Interactive Corp., 1 F.d, (th Cir. 0. Although the district courts in the Ninth Circuit have the discretion to use either one, the percentage-of-recovery method is preferable to the lodestar method because it encourages efficient resolution of the litigation by providing an incentive for early, yet reasonable settlement, it aligns the interests of class counsel directly with those of the class, and it reduces the demands on judicial resources. In re The hours of both Co-Lead and Liaison Counsel are examined in the fee analysis and award. See In Re Vioxx Products Liability Litigation, 0 F. Supp. d 0, - (E.D. La. 0; In Re Diet Drugs, F.d (d Cir md--mma (MDD

14 Brooktree Sec. Litig., 1 F. Supp., (S.D. Cal. ; see also In re Immune Response Sec. Litig., F. Supp. d, (S.D. Cal. 00 (noting the percentage of recovery method is commonly employed in this District. Regardless of which method is used, the fee award should take into account the particular factors in the specific case and must be reasonable under the circumstances. State of Florida v. Dunne, 1 F.d, (th Cir. 0 (recognizing a ground swell of support for mandating a percentage-of-the- fund approach in common fund cases. Accordingly, the percentage-of-recovery method is appropriate to determine whether a particular fee is proper. Under a percentage of a common fund analysis, whether the agreed-upon fee here (.% of the common financial benefit to the class is reasonable under the terms of the Settlement here is determined with reference to the following factors: (1 the results achieved; ( the risk of litigation ; ( the skill required and the quality of work; ( the contingent nature of the fee and the financial burden carried by the plaintiffs; and ( awards made in similar cases. See Vizcaino v. Microsoft Corp., 0 F.d, -0 (th Cir. 00. Applying these factors as discussed below, it is evident that the requested fee is reasonable. 1. The Court Can View the Totality of the Settlement s Value as a Common Fund and Award a Percentage of That Value. First, the Court may value the total amount of the benefit to the Class as if it were a common fund for purposes of awarding a fee. Here the result consists of cash, credits to accounts, payment of the costs of notice and claims administration and attorneys fees and litigation costs. The Ninth Circuit has routinely recognized the existence of a common fund consisting of relief beyond strictly cash, particularly where the parties agree on the value being provided. See Wing v. Asarco, Inc., F.d, 0 (th Cir. (calculating a common benefit to the class of $. million in case involving contamination of residential soil, consisting of a $00,000 fund for medical monitoring, $1. million to compensate for depreciation in -- -md--mma (MDD

15 property values, $ million in immediate cash payments, and a potential $0. million in payments dependent on defendant s recovery from its insurance carriers; Hanlon v. Chrysler Corp., F.d, (th Cir. (applying the percentage method to a common benefit comprised of $ million representing the amount the manufacturer charged against its earnings for the replacement and installation of defective door latches on minivans. Ultimately, the common fund doctrine applies and the percentage method can be utilized whenever: (1 the class of beneficiaries is sufficiently identifiable; ( the benefits can be accurately traced; and ( the fee can be shifted with some exactitude to those benefitting. See Paul, Johnson, Alston & Hunt v. Graulty, F.d, 1 (th Cir... Applying the Vizcaino Factors, Counsel Are Entitled to a Percentage of the Value of the Total Settlement. Applying the factors of Vizcaino, supra, it is evident that the requested fee as a percentage of the value of the recovery for the Class is reasonable. a. Class Counsel Achieved Exceptional Results for the Class. Plaintiffs counsel have negotiated an excellent settlement for the Class here. Ninth Circuit courts have long recognized that the result obtained by Class counsel is a principal factor in considering an enhanced lodestar multiplier. See, e.g., Kerr v. Screen Extras Guild, Inc., F.d, 0 (th Cir., cert. denied sub nom. Perkins v. Screen Extras Guild, Inc., U.S. 1 (. Here, the Settlement provides $1 million for the Settlement Class Members, divided between a $1 million credit component and a $ million cash component. In addition to the $1 million cash and credit benefit, Defendants are also paying $.1 to $. million to the Claims Administrator for notice and claims administration, a substantial benefit to the Class. Finally, separate and apart from the $1 million in cash and credits, and the more than $ million being paid for notice and claims administration, the Agreement provides for payment of an additional $. million in attorneys fees and costs. This excellent result for the Settlement Class in a highly contested case in -- -md--mma (MDD

16 which there was a high degree of uncertainty as to whether the Plaintiffs would have prevailed, supports the reasonableness of the fee request. The skill and experience of Plaintiffs counsel caused that result. Indeed, as of March 1, 01, out of the,,0 Notice Postcards mailed to class members, and publication notice in four national magazines and internet banner ads, only 1 out of some 1 million class members have sought to exclude themselves from the Settlement Class and only four people have objected to date, but none to the fees requested. So far, about,1 Settlement Class Members have submitted claims, which is approximately.% of the,,0 persons receiving direct mail notice postcards. For any consumer class action, that is at the high end of the percentages of claims expected to be made, and the claims deadline is still three weeks away. The high claims rate represents a ringing endorsement of the settlement and further justifies Class Counsel s request for fees. b. The Contingent Nature of This Case and the Risk Taken. This is not a fee shifting case as the TCPA does not provide for fee shifting. As such, this is not the type of case that would typically be pursued by counsel unless he or she had a reasonable expectation that a fee enhancement would be approved. No Plaintiff would likely pay any attorney s hourly rate if the potential recovery would be limited to the damages allowed by the TCPA, namely $00 for each incident if negligent or $1,00 if intentional. Thus, no attorney would likely take on such a case nor a client likely to be able to find any attorney to represent him or her in such a case. Campion Fee Decl., 1. The public interest is served by rewarding attorneys who agree to representation on a contingent basis with an enhanced fee to compensate them for the risk they might be paid nothing at all for their work. In Fadhl v. City and County of San Francisco, F.d (th Cir., a multiplier of was awarded in a Title VII case as the amount expected by attorneys in the local San Francisco market. The court found that a multiplier was necessary when the case would not -- -md--mma (MDD

17 have been filed by counsel without an expectation of a multiplier in the local market. Accord, Clark v. City of Los Angeles, 0 F.d, 1- (th Cir. ; Welch v. Metropolitan Life Ins. Co., 0 F.d, - (th Cir. 00; Fischel v. Equitable Life Assur. Society of U.S., 0 F.d, 0 (th Cir. 00; In re Wash. Pub. Power Supply Sys. Sec. Litig., F.d 1, (th Cir.. Here Class Counsel agreed to prosecute this case on a contingency with no guarantee of ever being paid, and they faced substantial risk that they would not obtain a favorable result. In agreeing to represent the Class on a contingent basis, Class Counsel risked their own resources with no guarantee of recovery, and in fact litigated this case for close to six years, without any payment in the interim and advancing all the litigation costs year after year. The risk that Class Counsel could recover nothing in this case, on its own, justifies the small percentage of the recovery sought as a fee award,.% of the settlement value. c. The Novelty and Difficulty of Questions Involved. The next Vizcaino factor dictates that the lodestar amount should be enhanced to account for the novelty and complexity of the questions involved. While Class Counsel were confident in their ability to succeed at class certification and at trial, success was by no means guaranteed, especially considering Defendants substantial opposition and the complexity of the issues involved. The claims in this case involved numerous issues of law that were complex, including consent, and class certification issues had the potential to present substantial problems. Furthermore, in these TCPA cases, plaintiffs always face the risk of not obtaining class certification based on the consent defense or not being able to prove that an automatic telephone dialing system was used. Such a risk of a substantial investment of time and resources in taking on such a case cannot be ignored. Nonetheless, Class Counsel agreed to represent the Class and, through their skill and substantial effort, successfully overcame formidable defenses to obtain excellent relief for the Class. / / / -- -md--mma (MDD

18 d. The Experience, Reputation and Ability of Counsel. The reputation, experience, and ability of Class Counsel were essential to the success of this litigation. As noted in the accompanying attorney declarations, Class Counsel have extensive experience in consumer class action and other complex litigation. Throughout this case, counsel have prosecuted the claims of consumers efficiently and effectively. (1 Law Offices of Douglas J. Campion, APC. Douglas J. Campion, one of Plaintiffs attorneys and co-lead Class Counsel, seeks fees at hourly rates of between $0 and $0 over the almost six-year period in which this case has been and will still be litigated. Campion Fee Decl., 1. As set forth in his declaration, Mr. Campion s extensive experience in class action litigation, including derivative and other consumer representative actions, over years of practice, justifies the hourly rate requested. Id. at -. Those hourly rates are below the rates charged in the community of attorneys doing this type of work with his level of experience and has been awarded fees at that hourly rate by this Court. Id. at 1-; Declaration of Frank Johnson In Support of Motion For Attorneys Fees and Costs ( Johnson Decl. filed herewith. ( Edelman, Combs, Latturner & Goodwin, LLC. James O. Latturner, and the law firm of Edelman, Combs, Latturner & Goodwin, LLC, one of Plaintiffs attorneys and co-lead Class Counsel, seek fees at hourly rates of between $ and $0. Latturner Fee Decl.,. As set forth in Mr. Latturner s declaration, his extensive experience ( years in legal practice, and the extensive experience of Edelman, Combs, Latturner & Goodwin, LLC ( years in legal practice in class action and consumer-related litigation, justifies the hourly rate requested. Id. at -. Mr. Latturner s rates and those of Edelman, Combs, Latturner & Goodwin, LLC as a whole are below the rates charged in the community of attorneys doing this type of work with comparable levels of experience and courts have awarded fees at the rates requested here. -- -md--mma (MDD

19 ( Law Office of David Schafer, PLLC. The Law Office of David Schafer, PLLC, which has been appointed Liaison Counsel in this case, seeks fees at hourly rates of $00 per hour for associates and $00 per hour for Mr. Schafer. Schafer Fee Decl.,,,. David Schafer, the principal of the Law Office of David Schafer, PLLC, has been practicing law for nineteen years, eleven of which he has been representing consumers in TCPA and other consumer related actions. As set forth in his declaration, Mr. Schafer s extensive experience justifies the hourly rate requested. Id., -. ( Kazerouni Law Group, APC. Kazerouni Law Group, APC is exclusively a consumer rights law firm. In this case, senior partner Abbas Kazerounian billed at $ per hour. He has litigated over 1,000 cases in the last five years and has been lead counsel on over 0 filed class actions with numerous published decisions (specifically in the area of TCPA. See Kazerounian Fee Decl., -. As detailed in that declaration, Mr. Kazerounian has been counsel on class actions in CA, TX and WA and as explained therein, his experience supports his requested hourly rate. ( Hyde & Swigart. Hyde & Swigart litigate consumer cases almost exclusively, having litigated over 00 cases over the past eight years. See Swigart Fee Decl. -1. In this case, senior partner Joshua B. Swigart billed at $ per hour. Id. at. As detailed in that declaration, the hourly rate sought by Joshua Swigart is supported by his experience. ( Warner Law Firm, LLC. The Warner Law Firm, LLC seeks fees at hourly rates of $0-$00 per hour. Warner Fee Decl., 1-1. Curtis Warner, the principal of the Warner Law Firm, LLC has been representing consumers for thirteen years and has been involved in a number of TCPA class actions. Id., -. As set forth in his declaration, Mr. Warner s experience in representing consumers in individual and class actions -- -md--mma (MDD

20 justifies the hourly rate requested. Class Counsel s skills in developing the factual and legal record and settling the case were essential to achieving this result. Moreover, Class Counsel s history of aggressive, successful prosecution of consumer class actions made credible their commitment to pursue this litigation until a fair result for the Class was obtained. Through their skill, reputation, and ability, Class Counsel were able to obtain a Judgment providing outstanding relief for the Class. e. The Risk Of Non-Payment And the Delay In Payment. A percentage of the recovery is warranted here due to the risk that Class Counsel took in prosecuting this case on a contingency basis and the significant delay in receiving payment. Here, the first two cases were filed on November, 0 (Robinson and December 1, 0 (Tovar respectively and the third case was filed on May, 0 (Scardina. Assuming the Court gives final approval to the settlement at the Final Approval Hearing on August, 01, it will be almost six years after the first case was filed before Plaintiffs counsel receive compensation for their efforts on behalf of the Settlement Class. This is an extraordinary length of time in which payment is not received. f. Awards Made in Similar Cases As for another Vizcaino factor, awards higher than % are regularly approved by courts in this District for similarly complex litigation. In fact, counsel are regularly awarded more than the % Ninth Circuit benchmark. See, e.g., In Re Pac. Enters. Sec. Litig., F.d, - (th Cir. (affirming 1/% fee; Vizcaino, 0 F.d at -0 (affirming % fee; Morris v. Lifescan, Inc., Fed. Appx., (th Cir. 00 (affirming % fee; In re Pub. Serv. Co. of New Mex., No. 1-0M, WL, * (S.D. Cal. July, (awarding % and finding awards traditionally ranged between 0% and 0% of the total recovery ; In re M.D.C. Holdings Sec. Litig., CV-000 E (M, 0 WL, * (S.D. Cal. Aug. 0, 0 (awarding a 0% fee, finding it to be -1- -md--mma (MDD

21 within the 0 0% range common to... contingent litigation.. Furthermore, the customary fees in these Telephone Consumer Protection Act cases are far higher than the fee sought here, as the % benchmark of a common fund case far exceeds the.% of the total benefit to the Class sought here. Furthermore, the award of attorneys fees in TCPA class actions is consistently between 0-% of the total fund available to the class, or its value. See Gutierrez, et al. v. Barclays Group, et al. (S.D. Cal.0 -.1% /. multiplier; Kramer v. Autobytel (N.D. Cal. 0 - % /. multiplier; Connor v. JPMorgan Chase (S.D. Cal % /. multiplier; Lozano v. Twentieth Century Fox (N.D. Ill.0 -.% /. multiplier; Arthur et al. v. Sallie Mae, Inc., (W.D. Wash. 0-0% /. multiplier; Rojas v. Career Educ. Corp. (N.D. Ill % /. multiplier. Counsel s fee request, therefore, for.% of the total value of the benefits to the Class is far less than what is typically awarded in either common fund or TCPA cases and, for that reason, should be approved.. In Addition, Many More Hours Will Be Incurred Before The Final Approval Hearing and Beyond, Further Justifying the Fee Request. As of March, 01, five months prior to the Final Approval Hearing, Plaintiffs counsel have incurred $1,,0.00 in attorneys fees based on their regular hourly rates. Class Counsel anticipate spending at a minimum dozens of additional hours of attorney time in the five months prior to the Final Approval Hearing and subsequent to that Hearing following up on Claims Administration. Thus, if the requested $. million fee is viewed as a percentage of the total settlement value of the common fund, $0,,0, the $,00,000 sought for fees and costs is only.% of that amount. That percentage is far below the Ninth Circuit s % percentage benchmark fee award in common fund cases. In Re Bluetooth Headset Products Liab. Litig., F.d, (th Cir. 0 (citing Six Mexican Workers, 0 F.d 1, 1 (th Cir. 0. Thus, as a percentage -1- -md--mma (MDD

22 of a common fund, the requested.% fee clearly falls within the range of reasonableness. Furthermore, as of March, 01, the $1,,0.00 lodestar is as of five months prior to the Final Approval Hearing. Class Counsel anticipate spending dozens of additional hours of attorney time in the five months prior to the Final Approval Hearing and subsequent to that Hearing following up on Claims Administration. For this reason and those set forth above, the Court should approve payment of $. million to Class Counsel as a reasonable percentage of the value of the settlement to the Class. B. If the Lodestar Analysis is Used, the Attorneys Fees Sought Result in a Multiplier of 1.1, Justified by the Kerr and Vizcaino Factors. If the Court decides to use a lodestar method to award fees, the amount requested is still reasonable and should be awarded, and the multiplier sought is justified under Ninth Circuit law. Vizcaino, supra, 0 F.d at -; Hanlon v. Chrysler Group, F.d, (th Cir.. Counsel seek the application of a 1.1 multiplier which, applied to their lodestar to date of $1,,0.00, yields the $. million fees and costs sought. The U.S. Supreme Court has explained that to calculate attorney s fees awards, the initial examination is to look at the number of hours expended multiplied by a reasonable hourly rate. Hensley v. Eckerhart, 1 U.S., (. See also Hanlon v. Chrysler Group, F.d, (th Cir. (The first step in calculating attorneys fees by the lodestar method is to multiply the number of hours counsel reasonably expended on the litigation by a reasonable hourly rate. In setting the lodestar rate this Court is required to consider the relevant factors discussed below and set forth in Kerr, supra, F.d at 0. As The court in Kerr identified twelve relevant factors to take into consideration: (1 the time and labor required; ( the novelty and difficulty of the questions involved; ( the skill requisite to perform the legal service properly; ( the preclusion of (continued md--mma (MDD

23 explained below, here the Kerr factors support the rate and lodestar multiplier requested. The Court need not discuss specifically each factor so long as the record shows that the court considered the factors implicated by the case at hand. Newhouse v. Robert s Ilima Tours, Inc., 0 F.d, 1 (th Cir.. 1. Counsel s Hourly Rates Are Reasonable and Are Consistent with Market Rates In determining a reasonable hourly rate, courts look to the prevailing market rates in the relevant community with close attention paid to the fees charged by lawyers of reasonably comparable skill, experience, and reputation. Davis v. City and County of San Francisco, F.d 1, 1 (th Cir., citing Blum v. Stenson, U.S., (. The firms experience is set forth in the section above explaining their skill and experience. Plaintiffs submit that the hourly rates charged by the firms that litigated this case on behalf of Plaintiffs and the Class are reasonable and within the range of hourly rates charged for the same services within the community. In addition to the National Law Journal chart regarding attorneys hourly rates discussed below, Plaintiffs have submitted a declaration of a local attorney who litigates in southern California and elsewhere and who is familiar with hourly rates charged in similar class and representative actions. (See Declaration of Frank Johnson In Support of Motion For Attorneys Fees and Costs ( Johnson Decl. filed herewith. Plaintiffs submit that the hourly rates charged here ranging (...continued other employment by the attorney due to acceptance of the case; ( the customary fee; ( whether the fee is fixed or contingent; ( time limitations imposed by the client or the circumstances; ( the amount involved and the results obtained; ( the experience, reputation, and the ability of the attorneys; ( the undesirability of the case; ( the nature and length of the professional relationship with the client; and (1 awards in similar cases. Kerr, F.d at 0. But see also Davis v. City & County of San Francisco, F.d 1, 1 (th Cir. ( the Supreme Court recently deemed irrelevant to the fee calculation a final Johnson-Kerr factor, the fixed or contingent nature of the fee md--mma (MDD

24 from $ to $0 are entirely fair and reasonable, given counsel s experience, qualifications and expertise. Those rates are well within the range of hourly rates charged for the same services within the southern California community. The hourly rates sought by the firms involved in this case are justified because they are lower than fees awarded to other Plaintiffs counsel with similar experience, and rates charged by other firms are indeed higher than the rates charged here. For example, attached as Exhibit 1 to the Campion Fee Decl. is the National Law Journal ALM Legal Intelligence chart of 01 Hourly Billing Rates listing rates charged by firms across the country. That chart shows many firms have hourly rates charged by senior partners in excess of the $0 charged here by both Mr. Latturner and Mr. Campion. In fact, of the firms listed have senior partner hourly billing rates at or above $0, with the highest rates at or above $1,00 per hour. Id.; Campion Fee Decl.. Similarly, many firms charge comparable rates or more for associate attorneys as charged by the Plaintiffs firms, with presumably less experience. It also must be remembered that those firms hourly fees are not contingent upon winning the case or settling on favorable terms. Class counsel set their rates for attorneys and staff members based on a variety of factors, including among others, the experience, skill and sophistication required for the types of legal services typically performed; the rates customarily charged in the markets where legal services are typically performed; and the experience, reputation and ability of the attorneys and staff members.. The Number of Hours Submitted by Counsel Is Reasonable. The second component of the lodestar figure is the number of hours counsel reasonably expended. The hours expended were reasonable. Knowing it was possible they would never be paid for their work, counsel had no incentive to act in a manner that was anything but economical. See Moreno v. City of Sacramento, F.d 0, 1 (th Cir. 00 ( [L]awyers are not likely to spend unnecessary time on contingency cases in the hope of inflating their fees. The payoff is too -1- -md--mma (MDD

25 uncertain, as to both the result and the amount of the fee.. That said, counsel here have taken their charge seriously and endeavored to represent the interests of the class members to the greatest extent possible. Plaintiffs are entitled to be compensated for all time that would, in the exercise of billing judgment, be billed to a fee-paying client. Hensley v. Eckerhart, supra, 1 U.S.,, ; Pennsylvania v. Delaware Valley Citizens Council for Clean Air, U.S. (. Each of the attorney declarations submitted summarize their firm s work, and they are also prepared to submit detailed time records upon the Court s request. The attached table summarizes the number of hours spent in this litigation, and the hourly rates charged, as set forth in the attorney declarations submitted. Law Firm Hours Rate Total Law Offices of Douglas J. Campion, APC Edelman, Combs, Latturner & Goodwin, LLC --Attorney Hours --Paralegal Hours.0 $0 - $0/hour $, $-$00/hour $1/hour $00,.0 $1,0.00 Law Office of David P.. $00-$00/hour $,.00 Schafer, PLLC Kazerouni Law Group, 1. $/hour $0,1.0 APC Hyde & Swigart. $/hour $0,01.00 Warner Law Firm, LLC.1 $0-$00/hour $0,.00 Totals,0.0 $1,,0.00 Plaintiffs counsel have expended about,0 hours in this litigation. With a lodestar of $1,,0.00, the requested fee of $,00,000 results in a multiplier of 1.1. / / / -md--mma (MDD

26 The general areas investigated, researched and litigated in this action to date detailed in the attorney declarations are summarized as follows. Before Scardina s case was transferred to this Court, Scardina and his counsel engaged in extensive discovery while the case was pending in Illinois. Proceedings in this Court included litigating the Robinson and Tovar cases prior to the MDL consolidation, including motion practice. After the MDL transfer, as shown in the lengthy docket report, the work involved organizing the Plaintiffs counsel leadership structure by applying to the Court for appointment of Interim Co-Lead Counsel and Liaison Counsel (ECF No. 1, drafting and filing a Consolidated Complaint (ECF No., briefing Defendants Motion to Stay on Primary Jurisdiction Grounds (ECF No. 0 which, after briefing and oral argument, the Court denied on January, 01. (ECF No.. Subsequent to that ruling, the Parties began protracted settlement discussions, including eleven sessions Judge Herbert B. Hoffman (Ret. of Judicate West, resulting in a settlement, approximately thirty months later. Additional time was spent memorializing a highly complex settlement, retaining a settlement administrator, and, after Notice went out, responding to dozens of s and telephone calls from Class Members. Thus, the hours claimed by Plaintiffs counsel are reasonable as they stand. See Perkins v. Mobile Housing Board, F.d, (th Cir. (attorney hours sworn to are evidence of considerable weight on the issue of the time required in the usual case and should not be reduced unless the time claimed is obviously and convincingly excessive under the circumstances. Additionally, Counsel exercised billing judgment. Attorneys normally do not bill all hours expended in litigation to a client, and a fee petition should reflect the exercise of billing judgment with respect to a claim of the number of hours worked. To show billing judgment, counsel for the prevailing party should make a good-faith effort to exclude from a fee request hours that are excessive, redundant, or otherwise unnecessary... [and the] district court has a corresponding obligation -1- -md--mma (MDD

27 to exclude hours not reasonably expended from the calculation. Jackson v. Austin, F.Supp. d, (D. Kan. 00 (citations omitted. In addition to the hours expended to date, and not included in the lodestar herein, Class Counsel anticipate incurring dozens of additional hours, in the approximate five months between the filing of this motion and the Final Approval Hearing, including working to determine the membership in each cash component or credit group, claims administration, preparing the Final Approval briefs and responding to objectors. Counsel will file a supplemental summary of time incurred prior to the Final Approval hearing, which will most certainly cause the multiplier for the fees incurred to date to decrease. Campion Fee Decl. 1. Thus, the amount of hours expended was reasonable.. A Multiplier Is Appropriate In This Case. The settlement here deserves an enhancement to the lodestar under Kerr. Ballen v. City of Redmond, F.d, (th Cir. 00; In re Wash. Pub. Power Supply Sys. Sec. Litig., F.d 1, n. (th Cir. ; Hanlon, supra, F.d at. See also Manual for Complex Litigation ( MCL th 1.1, at 1 (stating that upward adjustments to attorneys fees may be appropriate based on the results obtained, the quality of representation, the complexity and novelty of the issues presented, the risk of nonpayment, and any delay in payment. The Kerr factors clearly support the award of fees and a multiplier, as set forth below. (a The Kerr Factors Are Satisfied. Many of the Kerr factors are similar to those discussed under the Vizcaino analysis above and for sake of brevity, will not be repeated here but only summarized. The attorneys here were skilled and experienced, and obtained an excellent result a $0+ million benefit for the Class -- despite the fact that class certification with the consent issues may have been difficult. In addition, the customary fees awarded in these cases are far higher than the fee sought here, as the -- -md--mma (MDD

28 % benchmark of a common fund case far exceeds the.% of the total benefit to the Class sought here. The award of attorneys fees in TCPA class actions are consistently between 0-% of the total fund available to the class, or its value. See Awards Made in Similar Cases above at IV.. f, including the multipliers awarded in those cases. Furthermore, a multiplier is warranted here due to the significant risk Class Counsel took in prosecuting a case of this magnitude on a contingency basis, the significant delay in being compensated for their efforts, and the substantial opportunity costs in devoting so many hours over so many years to this case. Plaintiffs Counsel pursued this challenging case on a contingent basis, running a significant risk that they would not be compensated for significant time and money expended on the case. Given the case s challenges, including the vigorous opposition raised by Defendants counsel to Plaintiffs claims, Plaintiffs Counsel won t receive compensation for their efforts until six years have elapsed since the filing of the first case an extraordinary length of time. Finally, working on this case precluded at least the firms acting as co-lead counsel, and maybe others, from accepting other employment due to the time requirements of this case, as reflected in their more than,00 hours incurred to date. All these factors justify application of a modest 1.1 multiplier. Therefore, the Kerr factors dictate that a multiplier be granted. (b The Multiplier is within the Range of Reasonableness. The multiplier of approximately 1.1 sought here is certainly well within the range of reasonableness. Courts have awarded multipliers ranging from 0. to.. See Vizcaino v. Microsoft Corp., 0 F.d, 1 n. (citing cases; Steiner v. Am. Broad. Co., Fed. Appx. 0, (th Cir. 00 (approving. multiplier; In re Merry-Go-Round Enterprises, Inc., B.R. (Bankr. D. Md. 000 (0% award of $1. million fund; cross-check multiplier of.; In re Rite Aid Corp. Sec. Litig., F. Supp. d (E.D. Pa. 00 (% of $1,000,000 fund; multiplier of.; In re RJR Nabisco, Inc. Sec. Litig, WL 1 (S.D md--mma (MDD

29 N.Y Aug., (% of $. million; multiplier of. Applying the criteria and case law cited above, a 1.1 multiplier is warranted under these circumstances and an award of $. million in attorneys fees and costs is clearly justified here. See Vizcaino v. Microsoft Corp., 0 F.d at (affirming enhanced fee where counsel pursued this case in the absence of supporting precedents and against [Defendants s] vigorous opposition throughout the litigation. V. THE PAYMENT OF COSTS IS FAIR AND REASONABLE Plaintiffs also seek Court approval of their reimbursement of the litigation costs they incurred during the litigation, not from the Settlement Fund but from the $. million fees and costs award they seek. Plaintiffs counsel have incurred $,0.0 in costs to date. Case authority permits Plaintiffs counsel to be reimbursed for costs necessarily incurred in the litigation of the case. See In re Immune Response Sec. Litig., F. Supp. d, - (S.D. Cal. 00 (finding that costs such as filing fees, photocopy costs, travel expenses, postage, telephone and fax costs, computerized legal research fees, and mediation expenses are relevant and necessary expenses in a class action litigation. Furthermore, even though Plaintiffs counsel is not making such a request here, case law permits requiring class members to proportionately pay the costs associated with litigation of a class action. In re Media Vision Tech. Sec. Litig., 1 F. Supp. 1, 1 (N.D. Cal. (citing Mills v. Electric Auto-Lite Co., U.S., 1-, 0 S. Ct. 1, L. Ed. d (0. Instead, here Plaintiffs Counsel are seeking reimbursement of their costs from the $. million requested, and not asking the Class to pay any of those costs from the Settlement Fund. Assuming the Court grants the $. million request, from the gross payment the costs will be allocated to each firm based on the amount of costs each firm incurred and then the remainder will be divided as fees. / / / -1- -md--mma (MDD

30 Those costs were reasonably incurred in this litigation. As stated in the attorneys fee declarations filed herewith, the total costs incurred by Plaintiffs counsel in the three cases were $,0.0. A substantial portion of the costs were for the dozen or so mediation sessions with Judge Hoffman. In addition, the parties incurred substantial other litigation costs, including travel expenses to attend the mediations, filing fees, deposition costs, case specific on-line legal research fees, copying, mailing, and messenger expenses, and Information Technology expert consultant fees. See Id. Class counsel advanced these costs without assurance that they would ever be repaid. Campion Fee Decl.. These costs were necessary to secure the resolution of this litigation. The costs by the firm incurring them are as follows: Law Offices of Douglas J. Campion, APC: $,1. Edelman, Combs, Latturner & Goodwin, LLC: $1,0. Hyde & Swigart: $,1.1 The Kazerouni Law Group, APC: $,0. Law Office of David Schafer: $ 1,.1 Warner Law Firm, LLC: $.00 Total: $,0.0 If the Court desires to see the detailed summaries of the costs incurred, they will be provided. In light of the expenses Class Counsel has had to incur to bring this case to its current settlement posture, Class Counsel request that the Court confirm that Plaintiffs counsel may seek reimbursement for their costs incurred from the $. million fees and cost fund in the amount of $,0.0. Class Counsel is also seeking Court approval and an order requiring the payment of the approximately $.1-$. million charged by the Claims Administrator, KCC, for its notice and claims administration services. Class Counsel expects KCC will submit a final invoice prior to the Final Approval Hearing. As set forth in the Agreement, the Class will not pay any of this amount; Defendants have agreed to pay KCC s total fees and costs incurred separate from any other amounts being paid to the Settlement Class Members or to Class Counsel. Campion Fee Decl md--mma (MDD

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