Important Documents
For additional information on the Settlements, please select from the documents listed below.
Joint Motion for Approval of Settlement with Claimant China Chamber of International Commerce
Settlement Claims Administration Status Report - May 16, 2019
Order Approving the Motion for Disbursement of Funds
Plaintiffs' Response to Objections by Claimants
Supplemental Declaration of Michael R. O'Connor, Esq.
Memorandum in Support of Motion for Disbursement
Notice of Motion and Motion for Disbursement
Proposed Order on Briefing Schedule for Objections
Order on Briefing Schedule for Objections
Proposed Order on Motion and Motion for Disbursement
Declaration and Exhibits of Daniel Hedlund
Declaration and Exhibits of Michael O'Connor
- Declaration of Michael O'Connor
- Exhibit A to O'Connor Declaration: Declaration of Julie Redell July 26, 2013
- Exhibit B to O'Connor Declaration: Declaration of Julie Redell October 5, 2015
- Exhibit C to O'Connor Declaration: Declaration of Katherine Kinsella July 26, 2013
- Exhibit D to O'Connor Declaration: Declaration of Katherine Kinsella October 5, 2015
- Exhibit E to O'Connor Declaration Round 1 Claim Form
- Exhibit F to O'Connor Declaration Round 2 Claim Form
- Exhibit G to O'Connor Declaration Round 3 Claim Form
- Exhibit H to O'Connor Declaration Plan of Allocation
- Exhibit I to O'Connor Declaration Defective Claim Letter
- Exhibit J to O'Connor Declaration Multi-Submission Letter
- Exhibit K to O'Connor Declaration Conflicting Claim Letter
- Exhibit L to O'Connor Declaration Affidavit Request Letter
- Exhibit M to O'Connor Declaration UPS Express Letter
- Exhibit N to O'Connor Declaration DHL Express Letter
- Exhibit O to O'Connor Declaration 2A Letter
- Exhibit P to O'Connor Declaration Green Letter
- Exhibit Q to O'Connor Declaration Yellow Letter
- Exhibit R to O'Connor Declaration Orange Letter
- Exhibit S to O'Connor Declaration Phase 1 Data Request Letter
- Exhibit T to O'Connor Declaration Phase 1 Data Cure Letter
- Exhibit U to O'Connor Declaration Phase 2 Data Cure Letter
- Exhibit V to O'Connor Declaration Pro Rata Percentage Summary
- Exhibit W to O'Connor Declaration Inconsistent Claim Letter
- Exhibit X to O'Connor Declaration Determinations Table
- Exhibit Y to O'Connor Declaration Aggregate Claim Summary
- Exhibit Z to O'Connor Declaration Determination Letter
- Exhibit AA to O'Connor Declaration Settlement Funds
- Letter Updating The Court On Status Of Claims Administration
- List of All Defendants
- Plan of Allocation
- Third Amended Complaint – Redacted
- Fourth Amended Class Action Complaint - Redacted
- Order Approving Class Notice Program for Third and Final Round of Settlements
Notice and Claim Package Documents from the First Round of Settlements
Notice and Claim Package Documents from the Second Round of Settlements
Notice and Claim Package Documents from the Third Round of Settlements
Motions for Preliminary Approval of Settlements
- Motion for Preliminary Approval of Settlement with ABX Logistics Worldwide
- Memorandum Motion to Preliminary Approve Settlement with ABX Logistics Worldwide
- Declaration of Hedlund in Support of Preliminary Approval with ABX Logistics Worldwide
- Order Granting Preliminary Approval for Settlement with ABX Logistics Worldwide
- Motion for Preliminary Approval of Settlement with Expeditors International
- Memorandum - Motion to Preliminary Approve Settlement with Expeditors International
- Declaration of Bruckner in Support of Preliminary Approval with Expeditors International
- Declaration of Lovell in Support of Preliminary Approval with Expeditors International
- Order Granting Preliminary Approval for Settlement with Expeditors International
- Motion for Preliminary Approval of Settlement with Morrison Express Logistics
- Memorandum - Motion to Preliminary Approve Settlement with Morrison Express Logistics
- Declaration of Lovell in Support of Preliminary Approval with Morrison Express Logistics
- Order Granting Preliminary Approval for Settlement with Morrison Express Logistics
- Proposed Order Preliminarily Approving Proposed Settlements with Schenker/BaxGlobal/Vantec/EGL
- Memorandum - Motion to Preliminary Approve Settlement with Schenker/BaxGlobal/Vantec/EGL
- Declaration of Bruckner in Support of Preliminary Approval with Schenker/BaxGlobal/Vantec/EGL
- Declaration of Hedlund in Support of Preliminary Approval with Schenker/BaxGlobal/Vantec/EGL
- Declaration of Lovell in Support of Preliminary Approval with Schenker/BaxGlobal/Vantec/EGL
- Order Granting Preliminary Approval for Settlement with Schenker/BaxGlobal/Vantec/EGL
United Aircargo Consolidators, Inc
- Motion for Preliminary Approval of Settlement with United Aircargo Consolidators Inc
- Memorandum - Motion to Preliminarily Approve Settlement with United Aircargo Consolidators
- Declaration of Jaccarino in Support of Prelim Approval with United Aircargo Consolidators Inc
- Declaration of Lovell in Support of Prelim Approval with United Aircargo Consolidators Inc
- Order Granting Preliminary Approval for Settlement with United Aircargo Consolidators Inc.
- Motion for Preliminary Approval of 4 Settlements: Panalpina, Geodis, DSV & Jet Speed
- Memorandum for Preliminary Approval of 4 Settlements
- Declaration & Exhibit of Steven N Williams re Panalpina Settlement
- Declaration and Exhibits of W Joseph Bruckner re Jet Speed and Geodis Settlements
- Declaration and Exhibit of Daniel C Hedlund re DSV Settlement
- Order Granting Preliminary Approval of 4 Settlements: Panalpina, Geodis, DSV & Jet Speed
- Motion for Preliminary Approval of 4 Settlements: Panalpina, Geodis, DSV & Jet Speed
- Memorandum for Preliminary Approval of 4 Settlements
- Declaration & Exhibit of Steven N Williams re Panalpina Settlement
- Declaration and Exhibits of W Joseph Bruckner re Jet Speed and Geodis Settlements
- Declaration and Exhibit of Daniel C Hedlund re DSV Settlement
- Order Granting Preliminary Approval of 4 Settlements: Panalpina, Geodis, DSV & Jet Speed
- Motion for Preliminary Approval of 4 Settlements: Panalpina, Geodis, DSV & Jet Speed
- Memorandum for Preliminary Approval of 4 Settlements
- Declaration & Exhibit of Steven N Williams re Panalpina Settlement
- Declaration and Exhibits of W Joseph Bruckner re Jet Speed and Geodis Settlements
- Declaration and Exhibit of Daniel C Hedlund re DSV Settlement
- Order Granting Preliminary Approval of 4 Settlements: Panalpina, Geodis, DSV & Jet Speed
- Motion for Preliminary Approval of 4 Settlements: Panalpina, Geodis, DSV & Jet Speed
- Memorandum for Preliminary Approval of 4 Settlements
- Declaration & Exhibit of Steven N Williams re Panalpina Settlement
- Declaration and Exhibits of W Joseph Bruckner re Jet Speed and Geodis Settlements
- Declaration and Exhibit of Daniel C Hedlund re DSV Settlement
- Order Granting Preliminary Approval of 4 Settlements: Panalpina, Geodis, DSV & Jet Speed
- Motion for Preliminary Approval of Settlements with Defendants Agility Holdings, Inc., Agility Logistics Corp., Geologistics Corp., Geologistics International Management (Bermuda) Limited, United Parcel Service, Inc., and UPS Supply Chain Solutions
- Memorandum for Preliminary Approval of Settlements
- Declaration and Exhibits of W. Joseph Bruckner regarding the Settlements
- Order Granting Preliminary Approval of Agility, Geologistics and UPS Settlements
- Motion for Preliminary Approval of Settlements with Defendants Agility Holdings, Inc., Agility Logistics Corp., Geologistics Corp., Geologistics International Management (Bermuda) Limited, United Parcel Service, Inc., and UPS Supply Chain Solutions
- Memorandum for Preliminary Approval of Settlements
- Declaration and Exhibits of W. Joseph Bruckner regarding the Settlements
- Order Granting Preliminary Approval of Agility, Geologistics and UPS Settlements
- Motion for Preliminary Approval of Settlements with Defendants Agility Holdings, Inc., Agility Logistics Corp., Geologistics Corp., Geologistics International Management (Bermuda) Limited, United Parcel Service, Inc., and UPS Supply Chain Solutions
- Memorandum for Preliminary Approval of Settlements
- Declaration and Exhibits of W. Joseph Bruckner regarding the Settlements
- Order Granting Preliminary Approval of Agility, Geologistics and UPS Settlements
- Motion for Preliminary Approval of Proposed Settlement with the DHL Defendants and Conditional Certification of Settlement Class
- Memorandum In Support Of Plaintiffs’ Motion for Preliminary Approval of Proposed Settlement with the DHL Defendants and Conditional Certification of Settlement Class
- Declaration of W. Joseph Bruckner In Support of Motion for Preliminary Approval of Settlement with the DHL Defendants and Conditional Certification of Settlement Class
- Order Preliminarily Approving Proposed Settlement with the DHL Defendants and Certifying Settlement Class
- Notice of Motion for Preliminary Approval of Proposed Settlement with the Hellmann Defendants and Conditional Certification of Settlement Class
- Proposed Order Preliminarily Approving Proposed Settlement with Defendants Hellmann Worldwide Logistics GMBH & Co. KG, Hellmann Worldwide Logistics Ltd Hong Kong, and Hellmann Worldwide Logistics, Inc., and Certifying Settlement Class
- Memorandum in Support of Plaintiffs’ Motion for Preliminary Approval of Proposed Settlement with the Hellmann Defendants and Conditional Certification of Settlement Class
- Declaration of Daniel E. Gustafson in Support of Motion for Preliminary Approval of Settlement with the Hellmann Defendants and Conditional Certification of Settlement Class
- Certificate of Service
- Order Preliminarily Approving Proposed Settlement with Defendants Hellmann Worldwide Logistics GMBH & Co. KG, Hellmann Worldwide Logistics Ltd. Hong Kong, and Hellmann Worldwide Logistics, Inc. and Certifying Settlement Class
Motions for Final Approval of Settlements - 2013
- Plaintiffs’ Consolidated Memorandum of Law in Support of Final Approval of Ten Proposed Settlements and Plan of Allocation
- Plaintiffs' Reply to Non-Settling Japanese Defendants' Opposition to Motion for Final Approval of Vantec and Nishi-Nippon Settlements
- Opposition of Hewlett-Packard Company to Plaintiffs' Motion for Final Approval of Class Settlement with Schenker Defendants
- Objection of Non-Settling Japanese Defendants to Plaintiffs Settlement with Vantec and Plaintiffs Settlement with Nishi Nippon
- Notice of Motion and Hearing
- Non-Settling Japanese Defendants Opposition to Plaintiffs Motion for Final Approval of Settlements with Vantec and Nishi Nippon
- Letter to Judge fom Plaintiffs Regarding Courtesy Copies of Document
- Letter Regarding Settlement with Plaintiffs
- Letter Regarding Response Time Regarding Documents
- Letter Regarding Modified Preliminary Order Regarding Fee Petition
- Dell Inc.'s Response to Plaintiffs' Memorandum in Support of Final Approval
- Declaration of Katherine Kinsella
- Declaration of Julie Redell
- Dell Inc.'s Response to Plaintiffs' Consolidated Memorandum of Law in Support of Final Approval of Ten Proposed Class Settlements
- Order Granting Final Approval of Settlements and Supplemental Fee Application
- Plaintiffs' Reply to Non-Settling Japanese Defendants' Opposition to Motion for Final Approval of Vantec and Nishi-Nippon Settlements
Motions for Final Approval of Settlements - 2015
- Memorandum of Law & Attachments
- Memorandum of Law in Support of Plaintiffs' Motion to Finally Approve the Second Round of Settlements and Plan of Allocation
- Exhibit 1
- Exhibit 2
- Plan of Allocation
- Agility Settlement
- Dachser Settlement
- DHL Settlement
- DSV Settlement
- Geodis Settlement
- Japanese Defendants Settlement
- Jet Speed Settlement
- Panalpina Settlement
- SDV Settlement
- Toll Settlement
- UPS Settlement
- Notice of Motion & Attachments
- Notice of Motion and Motion for Final Approval of the Second Round of Settlements and Plan of Allocation
- Agility Proposed Order
- Dachser Proposed Order
- DHL Proposed Order
- DSV Proposed Order
- Geodis Proposed Order
- Japanese Defendants Proposed Order
- Jet Speed Proposed Order
- Panalpina Proposed Order
- SDV Proposed Order
- Toll Proposed Order
- UPS Proposed Order
- Declaration of Julie Redell
- Declaration of Katherine Kinsella
Motions for Final Approval of Settlements - 2016
- Memorandum of Law & Attachments
- Memorandum of Law in Support of Plaintiff's Motion to Finally Approve the Third Round of Settlements and the Plan of Allocation
- Exhibit 1
- Exhibit 2
- Exhibit 3
- Notice of Motion & Attachments
- Notice of Motion and Motion for Final Approval of the Third Round of Settlements and Plan of Allocation
- DHL Proposed Order
- Hellman Proposed Order
- Declaration of Kevin Skenandore
- Declaration of Shannon Wheatman
- Motion for Attorney's Fees
- Memorandum in Support of Attorney's Fees
- Declarations and Exhibits in Support of Attorney's Fees
-
Plaintiff Counsels’ Motion for a Second Interim Award of Attorneys’ Fees and Reimbursement of Expenses
- Plaintiff Counsels’ Motion for a Second Interim Award of Attorneys’ Fees and Reimbursement of Expenses
- Proposed Order Granting Co-Lead Counsel's Petition for a Second Interim Award of Attorneys’ Fees and Reimbursement of Expenses
- Memorandum in Support of Co-Lead Counsel's Petition for a Second Interim Award of Attorneys’ Fees and Reimbursement of Expenses
- Joint Declaration of Co-Lead Counsel in Support of Co-Lead Counsel's Petition for a Second Interim Award of Attorneys’ Fees and Reimbursement of Expenses
- Exhibit A
- Exhibit B
- Exhibit C
- Exhibit D
- Exhibit E
- Exhibit F
- Exhibit G
- Exhibit H
- Exhibit I
- Exhibit J
- Exhibit K
- Exhibit L
- Exhibit M
- Exhibit N
- Exhibit O
- Exhibit P
- Exhibit Q
- Exhibit R
- Certificate of Service
-
Co-Lead Counsel’s Motion For A Third Award Of Attorneys’ Fees And Reimbursement Of Expenses
- Co-Lead Counsel’s Notice Of Motion For A Third Award Of Attorneys’ Fees And Reimbursement Of Expenses
- Proposed Order Granting Co-Lead Counsel’s Petition For A Third Award Of Attorneys’ Fees And Reimbursement Of Expenses
- Memorandum In Support Of Co-Lead Counsel’s Petition For A Third Award Of Attorneys’ Fees And Reimbursement Of Expenses
- Declaration Of W. Joseph Bruckner In Support Of Co-Lead Counsel’s Petition For A Third Award Of Attorneys’ Fees And Reimbursement Of Expenses
- Exhibit A
- Exhibit B
- Exhibit C
- Exhibit D
- Exhibit E
- Exhibit F
- Exhibit G
- Exhibit H
- Exhibit I
- Exhibit J
- Exhibit K
- Exhibit L
- Exhibit M
- Certificate of Service
-
Motion to Grant Service Awards to Class Representatives
- Plaintiffs’ Notice of Motion and Motion to Grant Service Awards to Class Representatives
- Proposed Order on Plaintiff’s Notice of Motion and Motion to Grant Service Awards to Class Representatives
- Memorandum In Support of Motion for Approval of Service Awards to Class Representatives
- Declarations of Anything Goes LLC d/b/a Mailboxes Etc.
- Declaration of David Howell Product Design Inc. d/b/a David Howell & Company
- Declaration of Innovation 714, Inc
- Declaration of Inter-Global, Inc.
- Declaration of JCK Industries, Inc.
- Declaration of Kraft Chemical Company
- Declaration of Mary Elle Fashions d/b/a Meridian Electric
- Declaration of Mika Overseas Corporation
- Declaration of NORMA Pennsylvania, Inc.
- Declaration of Precision Associates, Inc.
- Declaration of Printing Technology, Inc.
- Declaration of RBX Industries, Inc.
- Declaration of Zeta Pharmaceuticals LLC
- Certificate of Service
- Declaration and Exhibits in Support of Supp Fee Application
- Plaintiffs Supplemental Fee Application and Expense Request
Orders for Final Approval, Final Judgment and Fees
- Order Granting Final Approval for the ABX Logistics Worldwide Settlement
- Order Granting Final Approval for the DHL Settlement
- Order Granting Final Approval for the EGL Settlement
- Order Granting Final Approval for the Expeditors Settlement
- Order Granting Final Approval for the Hellmann Settlement
- Order Granting Final Approval for the Kuehne + Nagel Settlement
- Order Granting Final Approval for the Morrison Express Logistics Settlement
- Order Granting Final Approval for the Nishi-Nippon Settlement
- Order Granting Final Approval for the Schenker Settlement
- Order Granting Final Approval for the United Aircargo Consolidators Inc Settlement
- Order Granting Final Approval for the UTi Settlement
- Order Granting Final Approval for the Vantec Settlement
- Order Granting Final Approval to Second Round Settlements, the Plan of allocation and the Fee Petition
- Order Granting Co-Lead Counsel’s Petition For A Third Award of Attorneys’ Fees and Reimbursement of Expenses
- Order Granting Plaintiffs’ Notice Of Motion And Motion To Grant Service Awards To Class Representatives
- Settlement Agreement - ABX Logistics Worldwide
- Settlement Agreement - EGL
- Settlement Agreement - Expeditors International
- Settlement Agreement - Kuehne + Nagel
- Settlement Agreement - Morrison Express Logistics
- Settlement Agreement - Nishi Nippon
- Settlement Agreement - Schenker
- Settlement Agreement - SDV
- Settlement Agreement - United Aircargo Consolidators, Inc
- Settlement Agreement - UTi
- Settlement Agreement - Vantec
- Settlement Agreement – Panalpina
- Settlement Agreement – Geodis
- Settlement Agreement – DSV
- Settlement Agreement – Jet Speed
- Settlement Agreement – Toll
- Settlement Agreement – UPS
- Settlement Agreement – DHL Japanese
- Settlement Agreement – Japanese
- Settlement Agreement – DHL Non-Severed Japanese
- Settlement Agreement – Agility/Geologistics
- Settlement Agreement – Dascher
- Settlement Agreement - Hellmann
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