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Case 1:08-cv-05668-JHR-KMW Document 108 Filed 02/18/13 Page 1 of 17 PageID: 1383

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW JERSEY


FREDRIC J. BAKER,

Plaintiffs,

v.

INTER NATIONAL BANK, et al.,

Defendants.






Civil Action No. 08-5668 (JHR/KMW)

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ORDER





AND NOW, this ___ day of _________, 2013, upon consideration of Plaintiff’s Motion

for Award of Attorneys’ Fees, Reimbursement of Expenses and Award to Class Representative,

and the response of Defendants, if any, it is HEREBY ORDERED, ADJUDGED AND

DECREED that Plaintiff’s counsel is awarded fees in the amount of $289,759.50 and costs in the

amount of $4,874.53. Class Representative Fredric J. Baker is awarded an individual settlement

award in the amount of $6,000.00. Defendants shall pay such sums in accordance with the terms

of the Settlement Agreement.








































BY THE COURT;

______________________________
JOSEPH H. RODRIGUEZ, U.S.D.J.

Case 1:08-cv-05668-JHR-KMW Document 108 Filed 02/18/13 Page 2 of 17 PageID: 1384

James A. Francis I.D. No. JF 6355
Mark D. Mailman, I.D. No. MDM 1122
John Soumilas, I.D. No. JS 0034
FRANCIS & MAILMAN, P.C.
Land Title Building, 19th Floor
100 South Broad Street
Philadelphia, PA 19110
(215) 735-8600

Attorneys for Plaintiff and Class



IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW JERSEY


FREDRIC J. BAKER,

Plaintiffs,

v.

INTER NATIONAL BANK, et al.,

Defendants.





Civil Action No. 08-5668 (JHR/KMW)

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PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES, REIMBURSEMENT OF

EXPENSES AND AWARD TO CLASS REPRESENTATIVE






Plaintiff Fredric J. Baker hereby moves this Court for an award of attorneys’ fees and

costs, as prevailing party in this class action settlement, and also for an award to the Class

Representative. The reasons supporting this Motion are set forth in the accompanying

Memorandum of Law and Declarations of Class Counsel.

Date: February 18, 2013





Respectfully submitted,


FRANCIS & MAILMAN, P.C.

/s/ James A. Francis
JAMES A. FRANCIS
100 South Broad Street, 19th Floor
Philadelphia, PA 19110
(215) 735-8600









Case 1:08-cv-05668-JHR-KMW Document 108 Filed 02/18/13 Page 3 of 17 PageID: 1385


DONOVAN AXLER, LLC
NOAH I. AXLER
1845 Walnut Street, Suite 1100
Philadelphia, PA 19103

(215) 732-6067





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James A. Francis I.D. No. JF 6355
Mark D. Mailman, I.D. No. MDM 1122
John Soumilas, I.D. No. JS 0034
FRANCIS & MAILMAN, P.C.
Land Title Building, 19th Floor
100 South Broad Street
Philadelphia, PA 19110
(215) 735-8600

Attorneys for Plaintiff and Class



IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW JERSEY


FREDRIC J. BAKER,

Plaintiffs,

v.

INTER NATIONAL BANK, et al.,

Defendants.





Civil Action No. 08-5668 (JHR/KMW)

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PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF

MOTION FOR ATTORNEYS’ FEES, REIMBURSEMENT OF EXPENSES

AND AWARD TO CLASS REPRESENTATIVE




I.


INTRODUCTION

Plaintiff Frederic J. Baker and Class Counsel petition this Court for approval of an award

of attorneys’ fees and reimbursement of litigation expenses in accordance with the Settlement

Agreement in this matter, preliminarily approved by Court Order entered November 13, 2012,

and now pending final approval. Plaintiff also moves for a service award as Class

Representative.

Class Counsel have devoted their time, skill, and resources to this matter wholly

contingent upon a successful outcome, taking significant risks to obtain the result for the Class.

Case 1:08-cv-05668-JHR-KMW Document 108 Filed 02/18/13 Page 5 of 17 PageID: 1387

Their efforts have achieved a successful outcome and have resulted in settlement benefits,

consisting of a cash value of $115,312.70, as well as enforceable practice changes by Defendants

Inter National Bank and Netspend Corporation. Solely as a result of Class Counsel’s

negotiations, Defendants have agreed to change the packaging of their Gift Cards at issue and to

remove the alleged misrepresentations that were the subject of the Amended Complaint.

Defendant has also agreed to pay Plaintiff’s reasonable attorneys’ fees, costs and out-of-

pocket expenses as awarded by this Court; has provided the management and legal function and

has funded the costs of notice and settlement administration; and, subject to court approval, has

agreed to an individual settlement award of $6,000.00 to Representative Plaintiff Fredric J.

Baker.

Class Counsel now, as compensation for their achievement and effort, and for accepting

the risk that there would be no recovery if they were not successful, request the Court approve

the portion of the settlement providing for attorneys’ fees of $289,759.50 and costs of $4,874.53.

As detailed below, Class Counsel’s efforts and risks clearly justify the requested award of

fees and reimbursement of expenses. In support of their application approving payment for fees

and reimbursement of costs and expenses, Class Counsel rely upon the Declarations

summarizing Class Counsels’ time and the expenses incurred on behalf of the Plaintiff and Class.

See attached Declarations of James A. Francis and Noah Axler in support of Class Counsels’

petition for fees and expenses, filed herewith.



The reaction of the Class supports the request for fees and expenses. The Notice

provided to Class members expressly informed them that Class Counsel would apply for an

award of attorneys’ fees and costs not to exceed $300,000. To date, no Class member has



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objected to the settlement or to the fee requested, which evidences both a satisfactory result and a

reasonable fee.



II.

PROCEDURAL HISTORY



The settlement in this matter is the result of years of motion practice, discovery, litigation

and settlement negotiations. This case was undertaken and pursued on a contingent basis and

represented a significant financial risk for Class Counsel.

The action originally asserted claims for violation of the New Jersey Consumer Fraud

Act (“NJCFA”), N.J.S.A. §56:8-2, the New Jersey Truth-in-Consumer Contract, Warranty and

Notice Act (“TCCWNA”), N.J.S.A. §56:12-15 and Unjust Enrichment against Defendants Inter

National Bank and Netspend Corporation. The Complaint alleged that Defendants violated the

rights of consumers by issuing “All Access Visa Gift Cards” that contained unlawful and

deceptive marketing representations about the cards and by overcharging consumers an

Administrative Fee associated with the cards. The Complaint asserted that the packaging of the

cards contained the following 3 misrepresentations about the cards, namely that:

(a)

the cards were “good through 11.09;”

(b)

“The funds [did] not expire”; and,

(c)

“The monthly administrative fee of $2.95 [would] be waived for the first 6

months from date of purchase.”

Moreover, Plaintiff alleged that Defendants were charging consumers Administrative

Fees in advance of the six month period before which Administrative fees would take effect and

excessively assessing an Administrative Fee of $4.95 as opposed the $2.95 Administrative Fee

represented.



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The matter was vigorously defended by Defendants, and the case entered into a period of

significant and seemingly unending motion practice. Defendants filed an initial motion to

dismiss (Doc. 25) after the original Complaint was filed and a second motion to dismiss (Doc.

44) after the Amended Complaint was filed. Defendants raised numerous legal defenses in their

motion regarding merits of Plaintiff’s claims, choice of law, constitutional standing and the

adequacy of the pleadings. Defendants also vigorously challenged the subject-matter jurisdiction

of the Court raising arguments about the amount in controversy relative to the limitations of the

Class Action Fairness Act (“CAFA”) (Doc. 53). Defendants further reasserted their motion to

dismiss after the Court permitted Plaintiff to conduct discovery on the amount in controversy,

and Defendants conceded that CAFA jurisdiction was present (Doc. 71-1). Plaintiff in turn

responded to these legal motions which required substantial research and consideration and time

spent briefing and arguing the legal issues. The Court heard several oral arguments related to the

subjects of Defendants’ motions.

The Court entered a Memorandum Opinion and Order on January 19, 2012 regarding the

legal issues raised on Defendants’ renewed motion to dismiss. See Baker v. Inter National Bank

et al., 2012 WL 174956 (D.N.J. Jan. 19, 2012). In its ruling, the Court dismissed Plaintiffs’

claims for violation of the TCCWNA and Unjust Enrichment. In addition, the Court held that

Plaintiff did not have standing to challenge Defendants’ first two alleged misrepresentations

outlined above. As such, Plaintiff was left with a CFA claim relating to Defendants’

overcharging of the Administrative Fee associated with the cards.



Thereafter, the parties began negotiations in earnest which involved numerous telephone

conferences between the parties. After approximately four months of negotiations, the parties

were able to reach general terms of a settlement that were acceptable to both parties in May



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2012, subject to documentation and working out details, and requested that the Court set

deadlines for seeking preliminary approval of the settlement.



The Notice available to Settlement Class members on the Settlement Administrators

website informed that Class Counsel intend to apply for an award of fees and costs not to exceed

$300,000. To date, no Class member has expressed any objection to the fee request.

III. CLASS COUNSELS’ FEE REQUEST SHOULD
BE APPROVED AS FAIR AND REASONABLE



A.

Class Counsel Are Entitled To A Reasonable Fee

While an award of attorneys’ fees is mandatory under the New Jersey Consumer Fraud

Act, N.J.S.A. 56:8-19 (“CFA”), the amount falls within the Court’s discretion, and turns upon

the unique factors of the case. See In re Computron Software, 6 F. Supp.2d 313, 323 (D.N.J.

1998); In re Prudential Ins. Co. Am. Sales Litig., 148 F.3d 283, 338 (3d Cir. 1998); MANUAL FOR

COMPLEX LITIG., FOURTH, § 14, at 184 (2004) (MANUAL). While the factors will vary from case

to case, those generally considered by the Court in making this determination may include: (i)

the time and effort applied to the matter by the plaintiff’s counsel; (ii) the difficulty of the

litigation; (iii) the contingent nature of the retainer; (iv) the standing, experience and expertise of

counsel; (iv) the reaction of the class members. See Computron Software, 6 F.Supp.2d at 323;

see also MANUAL at § 14.122, pp. 195-96.

There are two typical methods of calculating attorneys’ fees in class actions – the

percentage of recovery method and the lodestar method. See In re Prudential Insurance Co.

Sales Practices, 148 F.3d at 332. The lodestar method is more commonly applied in statutory

fee-shifting cases. Charles v. Goodyear Tire & Rubber Co., 976 F.Supp. 321, 323 (D.N.J. 1997).

Courts generally regard the lodestar method, which uses the number of reasonable
hours times a reasonable rate, as the appropriate starting point for statutory fee
shifting cases. “Because the lodestar award is decoupled from the class recovery,



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the lodestar assures counsel undertaking socially beneficial litigation … an
adequate fee irrespective of the monetary value of the final relief achieved for the
class.”


Charles, 976 F.Supp. at 323 (quoting GM Trucks, 55 F.3d at 821). Fee shifting or statutory fee

cases provide for mandatory attorneys’ fees, thereby penalizing the defendant and rewarding

plaintiffs’ counsel for socially beneficial litigation. In re Prudential, 148 F.3d at 332.

Appropriate attorney's fees under the New Jersey CFA may be allowed without regard to the

amount involved in underlying dispute. Wisser v. Kaufman Carpet Co., Inc., 188 N.J.Super. 574,

458 A.2d 119 (A.D.1983).

B.

A Lodestar Analysis Confirms That The Fee Requested is Reasonable

Here, the claim asserted arises under the fee-shifting provisions of the CFA. The

provision for attorney fees under the CFA is mandatory as a result of the legislation's intent to

encourage attorneys to take small claims in order to serve the important public policy behind the

statute. Cogar v. Monmouth Toyota, 331 N.J.Super. 197, 751 A.2d 599 (A.D.2000).

Under New Jersey law, a court can increase or decrease the lodestar fee in light of the

quality of work performed and the contingencies involved. Counsel faced a substantial risk of

losing this matter with the prospect of receiving no compensation; they bore the burden of a

delay in receiving attorneys’ fees because of the contingent nature of their services; they

rendered quality services and obtained an excellent result for the Class through the settlement.

Further, the result obtained benefits not only the members of the settlement class but also the

public at large, which is an additional significant consideration. MANUAL, at § 14.13, p. 197.

Nonetheless, even though the Defendants have agreed to pay a greater amount than Class

Counsel’s lodestar, Class Counsel do not seek an upward adjustment of their lodestar.



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The lodestar and expenses for counsel here as described in counsels’ respective

Declarations is as follows: for Francis & Mailman, P.C., $231,961.55 reflecting over 497.60

hours of attorney and paralegal time, and costs of $4,139.05 (see Appendix I); and, for Donovan

Axler, LLC, $62,672.48, reflecting over 113.5 hours of attorney and paralegal time, and costs of

$735.48 (see Appendix II). Time for all counsel totals $289,759.50, and costs total $4,874.53,

for a total amount of time and costs of $294,634.03.



1.

Hourly Rates

The hourly rates for the firms of Plaintiff’s counsel are well within the range of what is

reasonable and appropriate in this market. See Declarations of counsel filed attached hereto.

The hourly rates for the attorneys in the firms are the same as the regular current rates charged

for their services in their standard non-class matters, including both contingent and non-

contingent matters. There has not been any alteration or deviation from the firms’ hourly rates to

account for the added complexity or increased risk factor of this action. The attorneys

concentrate their practice in the area of consumer protection litigation. The hourly rates are

within the range charged by attorneys with comparable experience levels for consumer class

action litigation of a similar nature. See analysis of similar fee request in Barel v. Bank of

America, 255 F.R.D. 393, 403-04 (E.D. Pa. 2009) (awarding firms 1.35 multiplier of lodestar).

The history and biography of each firm is included in the Declarations.

2.

Hours Expended

In support of this motion, the Plaintiff has submitted many pages of detailed,

contemporaneously produced time records specifying the date of work performed, the attorney

performing the work, the nature of the work, the amount of time spent and the hourly rate

charged for the tasks. Included in the time records are reasonable, albeit conservative, estimates



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of the time expected to be spent on the case after the date of this Motion. This submission

readily meets this Circuit’s requirement of the degree of specificity required of a party seeking

attorneys’ fees in a percentage-of-recovery case. See Prudential, 148 F.3d at 341-43 (district

court found detailed time summaries unnecessary where it was merely using lodestar calculation

to double check fee award). Counsel’s submission also meets the requirements for a statutory

fee-shifting award. See Rode v. Dellarciprete, 892 F.2d 1177, 1190 (3d Cir. 1990) (specificity

required to extent necessary to determine if the hours claimed are unreasonable for the work

performed). The Declarations submitted herewith also set forth the basis for the division of labor

among the firms and their efforts to litigate the case in an efficient manner. There was no time

for which compensation is now requested in this case that was “excessive, redundant, or

otherwise unnecessary.” Hensley v. Eckerhart, 461 U.S. 424, 433 (1983). All the time

submitted was reasonably necessary to achieve the successful outcome for the Plaintiffs and the

Class, and fees should not be reduced simply because Plaintiff was not successful on every

contention in the litigation. Hensley, 461 U.S. at 436.

3.

Costs

The Declarations of counsel filed simultaneously herewith show that costs as set forth

therein were incurred in the prosecution of this case. The bulk of the costs related to filing fees,

legal and other research, copying and mail charges. All of the costs were advanced by Plaintiff’s

counsel and were necessarily incurred. Plaintiff should be awarded the unreimbursed costs in

full.

C.

This Action Was Taken On A Totally Contingent Basis

Another factor for the Court to consider in awarding fees is the contingent nature of the

litigation. Lindy Bros. Builders, Inc. of Philadelphia v. American Radiator & Standard Sanitary



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Corp., 487 F.2d 161 (3d Cir. 1973).1 Here, the litigation was totally contingent. Class Counsel

were unable to mitigate any of the risk of nonpayment and, in fact, were required to spend, or

incur obligations, to effectively litigate this case.



Class Counsel undertook a substantial commitment of time and money to prosecute this

class action. The Class itself risked nothing out-of-pocket.

D.

The Level of Success Achieved




Counsel obtained for the Class a very good result. Courts have consistently recognized

that the result achieved is a major factor to be considered in making a fee award. Hensley, 461

U.S. at 436. Given the nature of the litigation, the complicated issues involved, the first-

impression issues inherent in the case, the risks faced, the quality of the work performed, and the

rigorous defenses confronted, an award of the lodestar of Class Counsel unquestionably

represents an appropriate level of compensation for the success Class Counsel achieved. The

settlement obtains a substantial recovery for the Class, represents a tangible benefit for all those

Class members who could not otherwise retain any counsel to ensure their rights were protected,

benefitted the public at large through the change in Defendants’ marketing practices and is well

within the range for similar cases and provides for a recovery in an environment of serious,

practical risks and/or impediments to the ultimate success of the claims. Thus, the requested fee

is reasonable in relation to the benefit achieved.

E.

Proportionality is Not Appropriate in Assessing The Fee Request

Some courts have raised a concern in consumer protection cases as to whether the

requested fee is reasonable in light of the amount of the sums earmarked for class members.


1
Judge Posner compares the economics of contingency fee arrangements to the making of a loan.
Judge Posner points out that the interest rate on the “loan” of the attorneys’ services should be much
higher than the interest on a conventional loan because the risk of default (i.e., the risk of losing the case)
is much higher and the loan may be outstanding for many more years without payment. Richard Posner,
ECONOMIC ANALYSIS OF LAW, §219.9, at 534-35 (3d ed. 1986).



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However, the fact that the expected amount of $13.14 to be distributed to each individual Class

member may not be a great sum in relation to Plaintiff’s fee request does not make that request

unreasonable. Since Plaintiff prevailed on the statutory fee-shifting claim raised in the

Complaint, the fee award cannot be diminished to maintain some ratio between the fee and the

damages. United Auto Workers Local 259 Social Sec. Dept. v. Metro Auto Center, 501 F.3d 283,

291 (3d Cir. 2007, citing to Washington v. Philadelphia County Court of Common Pleas, 89 F.3d

1031,1041-42 (3d Cir. 1996). See also Sheffer v. Experian Information Solutions, Inc., 290

F.Supp.2d 538, 550-51 (E.D. Pa. 2003) (“proportionality analysis between the amount of

damages awarded and the amount of counsel fees requested … is an impermissible basis upon

which to reduce a fee award”); Bonett v. Education Debt Services, Inc., 2003 WL 21658267, *8

(E.D. Pa. May 9, 2003); Oslan v. Law Offices of Mitchell N. Kay, 232 F.Supp.2d 436, 444 (E.D.

Pa. 2002). This is especially true where, as here, a plaintiff has achieved a future benefit for a

class as well as the general public, in addition to monetary compensation.

Under fee-shifting statutes such as the CFA, the amount of attorney fees awarded is not

required to be proportionate to the amount of damages recovered. This is to encourage private

counsel to enforce important consumer rights legislation. Noting that Congress contemplated

that civil plaintiffs would act as private attorneys general, the Third Circuit has stated:

Congress provided fee shifting to enhance enforcement of important civil rights,
consumer protection, and environmental policies. By providing competitive rates
we assure that attorneys will take such cases, and hence increase the likelihood
that the congressional policy of redressing public interest claims will be
vindicated.


Student Public Interest Research Group of New Jersey v. AT&T Bell Laboratories, 842 F.2d

1436, 1449 (3d Cir. 1988). One of the basic realities of consumer litigation was recognized by



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the Fifth Circuit in McGowan v. King Inc., 661 F.2d 48, 51 (5th Cir. 1981), where the court

stated:



The borrower’s counsel did not inflate this small [Truth-In-Lending] case into a
large one; its protraction resulted from the stalwart defense. And although
Defendants are not required to yield an inch or to pay a dime not due, they may by
militant resistance increase the exertions required of their opponents and thus, if
unsuccessful, be required to bear that cost.


See also, Newman v. Piggy Park Enters., Inc., 390 U.S. 400, 402 (1968); Perry v. Fleet Boston

Financial Corp., 229 F.R.D. 105, 123 (E.D. Pa. 2005) (noting importance of awarding fees in

consumer protection class litigation that “addresses important consumer concerns that would

likely be ignored without such class action lawsuits [and] must be encouraged”).



The same principles apply here in the context of a settled case. While the fees sought by

Plaintiff’s counsel might be considered by some to be relatively large in relation to the amount of

the individual awards available to members of the Class, in actuality the fees are reasonable

under the circumstances.

F.

The Standing Of The Attorneys Involved

The attorneys involved in this case have reputations in Pennsylvania, New Jersey and

nationally for handling class action litigation. See attached Declarations. Class Counsel have

worked together in the past and worked together here in a coordinated manner to avoid

duplication of effort and achieve the settlement. Class Counsel have either described their

experience in their Declarations and/or included their firm biographies as exhibits submitted in

support of fees.

G.

The Absence of Objections



As indicated above, the notice disseminated to class members stated that Class Counsel

would seek an award of the counsel fees and costs not in excess of $300,000, subject to Court



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approval. With the exception of the costs of notice and settlement administration costs paid by

Defendant, costs and expenses were borne by Class Counsel to litigate this action. Out of all the

Class members receiving notice, no Class member has objected to payment of the requested fees

and cost reimbursement. The lack of any serious objection is a highly significant indicator of the

reasonableness of the fee request. See Perry, 229 F.R.D. at 124.



Class Counsel has worked diligently and has achieved this beneficial result through their

combined, coordinated efforts. Counsels’ ability to effectively bring this case to a conclusion

should be reflected in the awarding of the full fee requested.

IV. CLASS COUNSEL SHOULD BE REIMBURSED

THEIR REASONABLE EXPENSES




The efforts of Class Counsel have resulted in substantial common benefits to the class. In

doing so, Class Counsel incurred out-of-pocket expenses in the aggregate amount of $4874.53,

for filing, postage, travel, research and copying costs. See Declarations at Appendices I-II.

These costs are eminently reasonable in light of the nature of the action and the tasks that needed

to be performed.

V.

INDIVIDUAL SETTLEMENT AWARD



Plaintiff’s counsel also seeks this Court’s approval of a $6,000.00 individual settlement

award for Plaintiff Fredric Baker, for his willingness to undertake the risks of this litigation and

shoulder the burden of such litigation. In this case, there would be no benefit to Class members

if the Class representative had not stepped forward. Mr. Baker devoted time and energy to the

litigation, including reviewing documents and consulting with counsel as necessary, and totally

fulfilled his obligations as Class representative. Class Counsel therefore request that the Class

representative receive an individual settlement award of $6,000.00. This award represents

statutory damages under the CFA, as well as recognition of the benefit of the settlement Plaintiff



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has achieved for the Class. Class members were notified that Class Counsel would request an

award for Mr. Baker in this amount and no Class member objected.



This award is well within the range of awards made in similar cases. See McGee, 2009

WL 539893 at *18 ($3,500); Barel v. Bank of America, 255 F.R.D. at 402-403 ($10,000); Perry,

229 F.R.D. at 118 (awarding $5,000, and citing cases); Roberts v. Texaco, Inc., 979 F. Supp. 185,

188 (S.D.N.Y. 1997) (awarding $25,000 to $85,000 incentive awards). Accordingly, the award

requested for Mr. Baker should be approved.

VI. CONCLUSION



Under all the circumstances existing here, the request for an individual settlement award

for the Plaintiff and for fees and costs is more than reasonable. For all the foregoing reasons,

Plaintiff requests that the Court approve an individual settlement award for Mr. Baker in the

amount of $6,000 and award his counsel their reasonable attorneys’ fees and reimbursement of

expenses in the total amount of $294,634.03.



Date: February 18, 2013





Respectfully submitted,










FRANCIS & MAILMAN, P.C.

/s/ James A. Francis
JAMES A. FRANCIS
100 South Broad Street, 19th Floor
Philadelphia, PA 19110
(215) 735-8600

DONOVAN AXLER, LLC
NOAH I. AXLER
1845 Walnut Street, Suite 1100
Philadelphia, PA 19103

(215) 732-6067















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I, JAMES A. FRANCIS, do hereby certify that, on this date, I caused a true and correct

CERTIFICATE OF SERVICE

copy of the foregoing Motion to be served via the Court’s ECF Notification system upon the

following counsel of record:

Kelly S. Crawford, Esquire

Riker Danzig Scherer Hyland & Perretti, LLP

Headquarters Plaza

One Speedwell Avenue

Morristown, NJ 07962-1981



Attorneys for Defendants Inter National Bank

And Netspend Corporation

































































Dated: February 18, 2013


FRANCIS & MAILMAN, P.C.

/s/ James A. Francis
JAMES A. FRANCIS
Attorney for Plaintiff
Land Title Building, 19th Floor
100 South Broad Street

Philadelphia, PA 19110
(215) 735-8600



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