In re: Navistar 6.0 L Diesel Engine Products Liability Litigation

MOTION

N.D. Ill.April 10, 2013

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: NAVISTAR DIESEL ENGINE ) Case No. 11 C 2496 PRODUCTS LIABILITY ) MDL NO. 2223 LITIGATION ) This Document Relates to: All Cases PLAINTIFFS’ MOTION FOR ATTORNEYS’ FEES, EXPENSES, AND SERVICE AWARDS Plaintiffs1 have reached a settlement agreement with Defendant Ford Motor Company (“Ford”) to resolve this case, which the Court preliminarily approved on November 14, 2012, and which is set for a final approval hearing on May 22, 2013. (Dkt. 242.) In connection with this settlement, Ford has agreed not to oppose Plaintiffs’ application for attorneys fees’ up to $12,800,000, costs and expenses up to $1,250,000, and service awards to be allocated among the named plaintiffs up to a total of $150,000. (Dkt. 236-1 at II.I-J.) For the reasons set forth in Plaintiffs’ Memorandum in Support of this Motion, Plaintiffs respectfully request that the Court approve their application for these attorneys’ fees, expenses, and service awards. 1 Plaintiffs are Custom Underground, Inc., John Barrett, Scott and Heather Gray, Frank Brown Towing, Inc., Cecil and Tressie Fulton, Karl Strong, Dinonno Enterprises, Inc., d/b/a Cutting Edge Concrete Cutting, Charles Clark, Georgean Vogt, John Prebish, Steve Santilli, Anthony Mawyer, Gena Boggero, Carl Atwell, Phillip Marcum, and James Hutton. Case: 1:11-cv-02496 Document #: 256 Filed: 04/10/13 Page 1 of 3 PageID #:6054 2 Dated: April 10, 2013 Respectfully submitted, By: /s/ Michael A. Caddell Michael A. Caddell Cynthia B. Chapman Cory S. Fein Caddell & Chapman 1331 Lamar, Suite 1070 Houston TX 77010-3027 Telephone: (713) 751-0400 Facsimile: (713) 751-0906 MDL LEAD COUNSEL FOR PLAINTIFFS Case: 1:11-cv-02496 Document #: 256 Filed: 04/10/13 Page 2 of 3 PageID #:6055 3 CERTIFICATE OF CONFERENCE I hereby certify that on April 10, 2013, I conferred with Brian Anderson, counsel for Defendant Ford Motor Co., regarding this motion. Mr. Anderson advised that Ford does not oppose the motion. /s/ Cynthia B. Chapman CERTIFICATE OF SERVICE I hereby certify that on April 10, 2013, this document was filed electronically via the Court’s ECF system and thereby served on all counsel of record. /s/ Cynthia B. Chapman Case: 1:11-cv-02496 Document #: 256 Filed: 04/10/13 Page 3 of 3 PageID #:6056