d that she "qualifies as a class member, with standing to object." Id. at 3. But Jane Doe 7 has never submitted a claim and has instead only emailed Class Counsel to ask for money under the threat that she would file her Objection if she did not receive payment. By her own words, . None of her demand letters

xpenses not to exceed $2,500,000.00 plus interest earned on both amounts at the same rate as earned by the Global Settlement Fund. Since being named Class Counsel, BSF and EHL have expended considerable time and effort in the prosecution of this Litigation on a wholly contingent basis and have advanced the ex

fixed amount -- the total amount Defendants pay will be determined by the claims submitted by Class members -- and the fees and expenses awarded to Class Counsel, along with the incentive awards granted to the Named [*57] Plaintiffs, will not reduce the amount available for Class members. ECF No. 92 at 29. T

amount of $2,320,000, which is 31.5 percent less than their lodestar calculation of $3,387,328.75. ECF No. 86 at 22.' Defendants do not argue that Class Counsel is entitled to less than the lodestar amount, but instead argue that Plaintiffs' $3,387,328.75 lodestar calculation is itself incorrect, based on u

t of $121,187.50. ECF No. 86-81f 7. The firm also reports litigation expenses of $516.27. Id. ¶ 11. The attorneys represent that Boucher, LLP, lead Class Counsel, reviewed time records from the other Class Counsel firms "for accuracy and removal or time that, although incurred, the lawyers determined in thei

iability" rate adjustments would have on the lodestar. Using the Knapton Declaration's fee schedule, ECF No. 86-9 Ex. 2,9 the Court calculates that Class Counsel partners billed a total of 3,542.1 hours; that the "associate class," including associates, law clerks, local counsel, and of-counsel attorneys, bi

categories of legal work. See, e.g., ECF No. 86-2 Ex. 1. Plaintiffs also provide a chronological description of the work performed, collectively, by Class Counsel, including the investigation leading up to the drafting and filing of the first complaint, Plaintiffs' response to Defendants' motion to dismiss, t

d and fourth, and sixth Gunter factors weigh in favor of approving a fee award within the ranges sought by Plaintiffs and Defendants. As discussed, Class Counsel spent 5,100 hours over three years litigating this case, survived a motion to dismiss, and obtained a fair and reasonable settlement in a complex,

fixed amount -- the total amount Defendants pay will be determined by the claims submitted by Class members -- and the fees and expenses awarded to Class Counsel, along with the incentive awards granted to the Named [*57] Plaintiffs, will not reduce the amount available for Class members. ECF No. 92 at 29. T

amount of $2,320,000, which is 31.5 percent less than their lodestar calculation of $3,387,328.75. ECF No. 86 at 22.' Defendants do not argue that Class Counsel is entitled to less than the lodestar amount, but instead argue that Plaintiffs' $3,387,328.75 lodestar calculation is itself incorrect, based on u

t of $121,187.50. ECF No. 86-81f 7. The firm also reports litigation expenses of $516.27. Id. ¶ 11. The attorneys represent that Boucher, LLP, lead Class Counsel, reviewed time records from the other Class Counsel firms "for accuracy and removal or time that, although incurred, the lawyers determined in thei

categories of legal work. See, e.g., ECF No. 86-2 Ex. 1. Plaintiffs also provide a chronological description of the work performed, collectively, by Class Counsel, including the investigation leading up to the drafting and filing of the first complaint, Plaintiffs' response to Defendants' motion to dismiss, t

iability" rate adjustments would have on the lodestar. Using the Knapton Declaration's fee schedule, ECF No. 86-9 Ex. 2,9 the Court calculates that Class Counsel partners billed a total of 3,542.1 hours; that the "associate class," including associates, law clerks, local counsel, and of-counsel attorneys, bi

d and fourth, and sixth Gunter factors weigh in favor of approving a fee award within the ranges sought by Plaintiffs and Defendants. As discussed, Class Counsel spent 5,100 hours over three years litigating this case, survived a motion to dismiss, and obtained a fair and reasonable settlement in a complex,