The hearing on Plaintiff Rudy Ramirez’s (“Plaintiff”) Motion for Preliminary Approval of Class Action and PAGA Settlement is CONTINUED to November 5, 2020 at 2:00 p.m. in department CX102 to permit the parties to respond to the issues identified below.
Any supplemental briefing shall be filed at least nine (9) days before the continued hearing and respond to each of the points raised below. If required, an amendment to the settlement agreement (“Settlement Agreement” or “SA”) is directed, rather than an “amended joint stipulation,” so as to avoid use of limited Court time and resources. A redlined copy of any amended Notice Packet materials should also be submitted for the Court’s reference and convenience. As to the Settlement Agreement
1. Plaintiff’s counsel seeks attorneys’ fees of 1/3 of the Gross Settlement Amount
(“GSA”) (SA, ¶¶ 16, 50.) The GSA includes amounts paid by Defendant under the Direct Settlement Program, in which Plaintiff’s counsel admittedly had no involvement. (See