NATIONAL VETERANS LEGAL SERVICES PROGRAM et al v. UNITED STATES OF AMERICA

Filing 42

Unopposed MOTION for Approval of Revised Plan of Class Notice and Class Notice Documents by ALLIANCE FOR JUSTICE, NATIONAL CONSUMER LAW CENTER, NATIONAL VETERANS LEGAL SERVICES PROGRAM (Attachments: #1 Exhibit 1 - Email Notice, #2 Exhibit 1-A - BLACKLINE Email Notice, #3 Exhibit 2 - Postcard Notice, #4 Exhibit 2-A - BLACKLINE Postcard Notice, #5 Exhibit 3 - Website Notice, #6 Exhibit 3-A - BLACKLINE Website Notice, #7 Exhibit 4 - Online Exclusion, #8 Exhibit 5 - Printable Exclusion, #9 Exhibit 6 - Proposed Order, #10 Exhibit 6-A - BLACKLINE Proposed Order)(Narwold, William)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL VETERANS LEGAL
SERVICES PROGRAM, NATIONAL
CONSUMER LAW CENTER, and
ALLIANCE FOR JUSTICE, for themselves
and all others similarly situated,
Plaintiffs,

Civil Action No. 16-745 ESH

v.
UNITED STATES OF AMERICA,
Defendant.
PLAINTIFFS’ UNOPPOSED MOTION FOR APPROVAL OF
REVISED PLAN OF CLASS NOTICE AND CLASS NOTICE DOCUMENTS
On April 3, 2017, the parties received an email from the Court requesting a call with
parties to discuss questions about and revisions to the Proposed Plan of Class Notice (ECF Nos.
37 (Unopposed Motion) and 37-4 (Proposed Order)). The parties spoke with the Court by phone
on April 4, 2017. As requested, Plaintiffs file this Unopposed Motion for Approval of Revised
Class Notice Plan and Class Notice Documents.
Attached as Exhibit 1 is a revised version of the Email Notice (previously ECF 37-1).
Plaintiffs have revised this document to be consistent with the Court’s comments, and have
attached as Exhibit 1-A a blacklined version of the Email Notice, which shows the revisions.
Plaintiffs intend to send this notice in the body of an email. The sender’s name will appear as
PACER Fees Class Action Administrator, and the subject line of the email will be “PACER Fees
– Notice of Class Action Lawsuit.”
Attached as Exhibit 2 is a revised version of the Postcard Notice (previously ECF 37-2).
Plaintiffs have revised this document to be consistent with the Court’s comments, and have
attached as Exhibit 2-A a blacklined version of the Postcard Notice, which shows the revisions.

Attached as Exhibit 3 is a revised version of the long-form notice (previously ECF 37-3),
which will appear on the class website at www.PACERFeesClassAction.com. Plaintiffs have
revised this document to be consistent with the Court’s comments, and have attached as Exhibit
3-A a blacklined version of the Website Notice, which shows the revisions.
Attached as Exhibit 4 is a mock-up of an online exclusion form, which will be available
on the class website and hyperlinked in the email notice. Class members will be able to
complete and submit the form online.
Attached as Exhibit 5 is a printable exclusion form, which will be available on the class
website. Class members will be able to print the form, complete it by hand, and mail it to the
Class Administrator.
Attached as Exhibit 6 is a [Proposed] Order Approving Plan of Class Notice (previously
ECF 39-1). Plaintiffs have revised this document to be consistent with the Court’s comments,
and have attached as Exhibit 6-A a blacklined version of the [Proposed] Order Approving Plan
of Class Notice, which shows the revisions.
Plaintiffs respectfully request that the Court grant Plaintiffs’ Unopposed Motion for
Approval of Revised Class Notice Plan and Class Notice Documents.

Dated: April 13, 2017

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Respectfully submitted,
By: /s/ William H. Narwold
MOTLEY RICE LLC
William H. Narwold
[e-mail]
DC Bar No. 502352
One Corporate Center
20 Church Street, 17th Floor
Hartford, CT 06103
Telephone: [phone]
Facsimile: [phone]

GUPTA WESSLER PLLC
Deepak Gupta, Esq.
[e-mail]
Jonathan E. Taylor
[e-mail]
1735 20th Street, NW
Washington, DC 20009
Telephone: [phone]
Facsimile: [phone]

Class Counsel

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CERTIFICATE OF SERVICE
I, William H. Narwold, declare that I am over the age of eighteen (18) and not a party to
the entitled action. I am a principal of the law firm MOTLEY RICE LLC, and my office is located
at One Corporate Center, 20 Church Street, 17th Floor, Hartford, CT 06103.
On April 13, 2017, I caused to be filed the following in the above-captioned case:
Plaintiffs’ Unopposed Motion for Approval of
Revised Plan of Class Notice and Class Notice Documents
with the Clerk of Court using the Official Court Electronic Document Filing System, which served
copies on all interested parties registered for electronic filing.
I declare under penalty of perjury that the foregoing is true and correct.

Dated: April 13, 2017

Respectfully submitted,
By: /s/ William H. Narwold
William H. Narwold
MOTLEY RICE LLC

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