Kardonick v. JP Morgan Chase & Co. et al

Filing 362

Plaintiff's MOTION for Leave to File Excess Pages for Lead Plaintiffs Motion for Final Approval of Settlement by David Kardonick. (Attachments: # 1 Exhibit A)(Ku, Brian)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
DAVID KARDONICK, individually and on
behalf of all others similarly situated and the
general public,
Plaintiff,

CASE NO.: 1:10-cv-23235/HOEVELER
CLASS ACTION

vs.
JPMorgan Chase & Co. and
Chase Bank USA, N.A.,
Defendants.
_________________________________________ /
PLAINTIFF’S MOTION TO EXCEED THE PAGE LIMITATION FOR LEAD
PLAINTIFF’S MOTION FOR FINAL APPROVAL OF SETTLEMENT
Pursuant to Local Rule 7.1(c)(2) Lead Plaintiff respectfully requests leave to exceed the
twenty page limitation for Lead Plaintiff’s Motion for Final Approval of Settlement and
Incorporated Memorandum of Law.
On February 3, 2011, this Court issued an Order (1) Conditionally Certifying a
Settlement Class, (2) Preliminarily Approving Class Action Settlement, (3) Approving Notice
Plan, and (4) Setting Fairness Hearing. [DE 23.] In that Order, the Court set a Fairness Hearing
for September 9, 2011, and ordered that all papers in support of settlement be filed and served
fourteen calendar days prior to that hearing. Pursuant to that Order, Lead Counsel has drafted a
Motion for Final Approval of Settlement and Incorporated Memorandum of Law that is
approximately fifty double-spaced pages. Lead Plaintiff asserts that the extra pages are necessary
to adequately address the issues raised in the Motion. Accordingly, Lead Plaintiff respectfully
requests leave to exceed the twenty page limitation for Lead Plaintiff’s Motion for Final

Approval of Settlement and Incorporated Memorandum of Law. A proposed order is attached
hereto as Exhibit A.
RULE 7.1.A.3 CERTIFICATION
Pursuant to Local Rule 7.1.A.3, Lead Plaintiff’s counsel contacted Defendants’ counsel
in order to determine whether they object to this Motion, and they do not object.

Respectfully Submitted,
Dated: August 25, 2011

Ku & Mussman, P.A.

/s/ Brian Ku
Brian Ku (FL Bar # 610461)
Louis Mussman (FL Bar # 597155)
M. Ryan Casey (LA Bar #30192)
12550 Biscayne Blvd., Suite 406
Miami, Florida 33181
Tel: [phone]
Fax: [phone]
[e-mail]
Richard M. Golomb
Ruben Honik
Kenneth J. Grunfeld
GOLOMB & HONIK, P.C.
1515 Market Street, Suite 1100
Philadelphia, PA 19102
Tel: [phone]
[e-mail]
Allen Carney
Randall K. Pulliam
Tiffany Wyatt Oldham
CARNEY WILLIAMS BATES
PULLIAM & BOWMAN LLC
11311 Arcade Drive, Suite 200
Little Rock, AR 72212
Tel: [phone]
Fax: [phone]

Allan Kanner
Conlee S. Whiteley
KANNER & WHITELEY, L.L.C.
701 Camp Street
New Orleans, Louisiana 70130
Tel: [phone]
[e-mail]
ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 25th day of August, 2011, I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document
is being served this day on all counsel of record or pro se parties in the manner specified, either
via transmission of Notices of Electronic Filing generated by CM/ECF or in some other
authorized manner for those counsel or parties who are not authorized to receive electronically
Notices of Electronic Filing.

By: /s/ Brian Ku
Brian Ku