UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA. Misc. No. 08-mc-0511 (PLF)

Similar documents
Case 1:08-mc PLF Document 379 Filed 08/19/13 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) )

JUDGE WATSON'S NOTICE OF COMPLIANCE WITH OMNIBUS ORDER ON PENDING MOTIONS DATED DECEMBER 20, 2013

Position Paper on Pigford Legislation Federation of Southern Cooperatives/Land Assistance Fund June 19, 2008

Case 1:04-cv LTS-HBP Document 746 Filed 10/24/18 Page 1 of 11

Case 3:09-cv N Document 1924 Filed 10/17/13 Page 1 of 4 PageID 52653

Case 1:00-cv RBW Document 249 Filed 06/11/15 Page 1 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:11-cv CM Document 79 Filed 11/07/14 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT NEW YORK

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case VFP Doc 24 Filed 09/05/17 Entered 09/05/17 17:38:55 Desc Main Document Page 1 of 9

Case 2:10-md CJB-SS Document 1308 Filed 02/17/11 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

IN THE SUPREME COURT OF FLORIDA CASE NO. SC THIRD DISTRICT CASE NO. 3D BRASS & SINGER, D.C., P.A., A/A/O MILDRED SOLAGES, Petitioner,

Case 1:11-cv SS Document 274 Filed 09/08/17 Page 1 of 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN

Filing # E-Filed 02/14/ :18:22 PM

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION

STAND-UP MRI OF ORLANDO, CASE NO.: CVA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION CLASS ACTION

Request for Proposals - Solicitor

Case 2:10-md CJB-SS Document 6239 Filed 04/13/12 Page 1 of 8 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

Case 1:04-cv LTS-HBP Document 745 Filed 10/24/18 Page 1 of 4 PLAINTIFFS MOTION FOR DISTRIBUTION OF THE NET SETTLEMENT FUND

Case MFW Doc Filed 12/03/18 Page 1 of 4 KYLE LAW CORPORATION. San Francisco, California December 3, 2018

Case 1:90-cv JLK Document 2537 Filed 11/06/18 USDC Colorado Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

STATE OF FLORIDA DIVISION OF ADMINISTRATIVE HEARINGS OFFICE OF THE JUDGES OF COMPENSATION CLAIMS DAYTONA BEACH DISTRICT OFFICE ) ) ) ) ) ) ) ) ) ) )

Case MFW Doc Filed 01/04/19 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In JAMS. Amended Class Action Demand for Arbitration

Case 3:09-cv N Document 2700 Filed 03/22/18 Page 1 of 6 PageID 80236

IN THE SUPREME COURT OF FLORIDA CASE NO. SC08-1. MARK FREEMAN and RAPHAEL RODRIGUEZ. Petitioners, vs. BLOSSOM COHEN and ABRAHAM COHEN, Respondents

Case 4:08-cv RP-CFB Document Filed 12/05/17 Page 1 of 12

Case: Document: 27 Page: 1 Filed: 06/05/

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO CIV-DIMITROULEAS

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. v. CASE NO AH

IN THE COURT OF APPEAL FIRST DISTRICT, STATE OF FLORIDA

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA

Case 1:12-cv DJC Document 295 Filed 07/13/17 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS (BOSTON)

Case: 1:08-cv Document #: 682 Filed: 02/21/18 Page 1 of 14 PageID #:29381

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK NOTICE OF LEAD PLAINTIFFS MOTION FOR APPROVAL OF DISTRIBUTION PLAN

IN THE DISTRICT COURT OF APPEAL THIRD DISTRICT, STATE OF FLORIDA

Case 8:15-bk MW Doc 28 Filed 11/03/15 Entered 11/03/15 13:17:18 Desc Main Document Page 1 of 6

NEW ISSUE - BOOK-ENTRY ONLY

CITY OF DALLAS DALLAS WATER UTILITIES COMMERCIAL PAPER PROGRAM SELECTION OF SERVICE PROVIDERS. BUDGET, FINANCE & AUDIT COMMITTEE June 2, 2014

Case 1:09-md PKC Document 1031 Filed 08/29/17 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

COMPARISON OF ARBITRATION RULES COMPARISON OF ARBITRATION RULES ICC UNCITRAL KLRCA. HKIAC HONG KONG INTERNATIONAL

BRIEF OF THE ACADEMY OF FLORIDA TRIAL LAWYERS, AMICUS CURIAE, SUPPORTING RESPONDENTS' POSITION

U.S. District Court Southern District of New York (Foley Square) CIVIL DOCKET FOR CASE #: 1:12-cv RWS

DISTRICT OF COLUMBIA OFFICIAL CODE

Doc 29 Filed 03/19/17 Entered 03/19/17 19:40:09 Main Document Pg 1 of 7

IN THE SUPREME COURT OF FLORIDA Case No.: SC L.T. Nos.: 5D , 5D

From Article at GetOutOfDebt.org

A federal court authorized this Notice. This is not a solicitation from a lawyer.

Appellant, Lower Court Case No.: CC O

smb Doc Filed 09/27/18 Entered 09/27/18 13:05:26 Main Document Pg 1 of 12

Case 3:09-cv N-BQ Document 201 Filed 05/16/17 Page 1 of 13 PageID 3204

IN THE SUPREME COURT OF FLORIDA. STATE FARM MUTUAL AUTOMOBILE Case No.: SC INSURANCE COMPANY, L.T. No.: 5D

PLAINTIFFS NOTICE OF SUPPLEMENTAL AUTHORITY. Plaintiffs P & S Associates, General Partnership ( P&S ), S & P Associates, General

Case 1:00-cv RBW Document Filed 04/12/16 Page 1 of 49. United States Department of Agriculture Office of Inspector General

March 7, The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426

Case 2:18-bk ER Doc 1263 Filed 01/16/19 Entered 01/16/19 11:51:44 Desc Main Document Page 1 of 6 UNITED STATES BANKRUPTCY COURT

Blake Morgan. Employment Tribunal Fees Guide. For Businesses

BROAD and CASSEL One Biscayne Tower, 21st Floor 2 South Biscayne Blvd. Miami, Florida

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

*** N E W O P E N A C C O U N T A P P L I C A T I O N * * *

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Case bjh11 Doc 168 Filed 12/20/18 Entered 12/20/18 12:51:25 Page 1 of 9

No CV. In the Fifth Court of Appeals Dallas, Texas

NOTICE OF PENDING CLASS ACTION PLEASE READ THIS NOTICE CAREFULLY AS YOUR LEGAL RIGHTS MAY BE AFFECTED.

UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE

Likely cost of using our services in unfair and wrongful dismissal claims in the employment tribunals.

Case: 1:17-cv Document #: 147 Filed: 04/20/18 Page 1 of 7 PageID #:2081 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS

Case 4:11-cv Document 143 Filed in TXSD on 06/25/13 Page 1 of 5

In the United States Court of Appeals for the Seventh Circuit

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

Case hdh11 Doc 223 Filed 12/26/17 Entered 12/26/17 15:19:42 Page 1 of 163

NOTICE AS TO PLAINTIFF S ENTITLEMENT TO DECLARATORY RELIEF

Table of Contents 01 Amendments to Bankrkuptcy Rules eff redlined 02 New Rules Dec 2017 Talking Points from Judge Wise1 03 Final Proposed Ch

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Case 1:18-cv LY Document 16 Filed 05/31/18 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

**ORAL ARGUMENT SCHEDULED FOR DECEMBER 8, 2017** IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

NO UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT UNITED STATES OF AMERICA, ANDREW AUERNHEIMER,

No U IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT

IN THE SUPREME COURT OF FLORIDA. Case No. SC08- Lower Tribunal No. 3D BEATRICE PERAZA, Appellant, vs. CITIZENS PROPERTY INSURANCE CORPORATION,

The only way to get a payment. NO LATER THAN MARCH 10, 2011 EXCLUDE YOURSELF NO LATER THAN MARCH 10, 2011 SUBMIT A CLAIM FORM

Case CSS Doc 16 Filed 08/26/14 Page 1 of 9 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Case 3:14-cv JAG-RCY Document 218 Filed 05/30/17 Page 1 of 12 PageID# 9162

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATED BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION. Civil Action No. 4:11-cv-655

Case 1:10-cr RJL Document 11 Filed 05/02/13 Page 1 of 5

IN THE DISTRICT COURT OF APPEAL FIFTH DISTRICT, STATE OF FLORIDA

BEFORE THE DISCIPLINARY BOARD OF THE SUPREME COURT OF PENNSYLVANIA : : : : : : : : No. 691, Disciplinary Docket No.

Case KG Doc 824 Filed 09/09/16 Page 1 of 24 UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE. Chapter 11

CUMMINS INC. S RESPONSE TO DEBTORS 110TH OMNIBUS OBJECTION TO CLAIMS (CONTINGENT CO-LIABILITY CLAIMS)

ORAL ARGUMENT HELD APRIL 12, 2016 IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

In this PIP case, State Farm Mutual Auto Insurance Co. (State Farm), the Defendant below,

2010 SUMMARY ANNUAL REPORT December 2011

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

IN THE SUPREME COURT OF FLORIDA Case No. SC Fifth DCA Case No. 5D10-19, Lake County

IN THE SUPREME COURT OF FLORIDA (Before a Referee)

11/10/2017 4:52:44 PM. Received by NSD/FARA Registration Unit. Received by NSD/FARA Registration Unit 11/10/2017 4:52:44 PM I--REGISTRANT

NOTICE OF CLASS ACTION, PROPOSED SETTLEMENT AGREEMENT, AND SETTLEMENT FAIRNESS HEARING

Case 3:17-cv JAG Document 29 Filed 02/07/18 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

Transcription:

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA In re BLACK FARMERS DISCRIMINATION LITIGATION This document relates to ALL CASES Misc. No. 08-mc-0511 (PLF STATUS REPORT OF CLASS COUNSEL REGARDING PROJECTED TIMELINE FOR COMPLETION OF CLAIMS PROCESS Lead Class Counsel respectfully submit this brief status report to apprise the Court of the expected timeline for the completion of the claims process established by the Settlement Agreement in the above-captioned case and to provide the Court with the projection that it is highly likely that there will be sufficient Settlement Funds to pay all prevailing Class Members the full amount of the award authorized by the Settlement Agreement. Lead Class Counsel have been advised by the Claims Administrator that all of the Track A and Track B Claims qualifying for a review on the merits by the Court-appointed Neutrals have now been provisionally adjudicated. All claims provisionally approved by the Neutrals are being further reviewed in order to: (a identify situations where multiple provisionally approved claimants have submitted claims relating to a single farming operation (so that the single award which any single farming operation is entitled to receive under the Settlement Agreement can be apportioned among such multiple approved claimants; (b identify situations where multiple provisionally approved claim submitters have submitted claims relating to a single estate (so that the single award which any estate is entitled to receive under the Settlement Agreement will be

transmitted only to the claim submitter (if any who is able to demonstrate that he/she has been appointed as the legal representative of the estate; (c identify situations where multiple provisionally approved claim submitters have submitted claims relating to a single incapacitated person (so that the single award which such an incapacitated person is entitled to receive under the Settlement Agreement will be transmitted only to the claim submitter (if any who is able to demonstrate that he/she has been appointed as the legal representative of the incapacitated person; (d identify any provisionally approved claimants who are not Class Members because, on further review, it is determined that they had participated in the Pigford I settlement process; and (e to apply additional quality control measures to ensure that only claims that satisfy the requirements of the Settlement Agreement are approved. It is currently projected that this final review process will be completed by July 19. The Claims Administrator has further advised Lead Class Counsel of the following provisional claims adjudication results. It is anticipated that these numbers will decline somewhat as the final review process is completed; it is not anticipated that these numbers would increase. 1. A total of 17,525 claimants to date have had their Track A claims provisionally approved for payment of a full Track A Liquidated Award of $50,000 plus a corresponding Tax Award of $12,500. 2. An additional 800 claimants to date have had their Track A claims provisionally approved for payment of a share of a Track A Liquidated Award. It has been provisionally determined that these 800 claimants would share a portion of 369 Track A Liquidated Award payments plus a corresponding Tax Award. 2

3. Eight additional claimants who have their Track A claims provisionally approved for payment have been provisionally determined to be entitled to ½ of a Track A Liquidated Award plus a corresponding Tax Award because of the $50,000 per individual limitation established by Section V.A.5 of the Settlement Agreement for claimants having an interest in multiple farming operations. 4. No Track B awards will be made. 5. While the number of Track A claimants who will receive a Track A Loan Award is still being confirmed, that number is expected to be no more than 15, and the potential total of all Track a Loan Awards together with the corresponding Track A Tax Award will not exceed $1,800,000. Based on these determinations, Lead Class Counsel project that the total amount of the Track A Liquidated Awards, Track A Loan Awards, and Track A Tax Awards for prevailing Class Members will not exceed $1,120,425,000. Once the final review process is completed and the Claims Administrator confirms the number of prevailing Track A claimants who will receive a Track A Loan Award and the amount of their awards (which is expected to take place by July 19, the next step in the implementation of the Settlement Agreement is for the Claims Administrator to prepare and then file with the Court the Preliminary Final Accounting required by Section V.E.7 of the Settlement Agreement. To prepare this accounting, the Claims Administrator is required to determine the Implementation Costs incurred to date and a good faith estimate of future Implementation Costs. Pursuant to Section II.I of the Settlement Agreement, the total Implementation Costs may not, without court approval, exceed $35 million. The Claims Administrator must also determine the Ombudsman Costs incurred to date and a good faith estimate of Ombudsman Costs necessary for 3

the Ombudsman to perform its final duties under this Agreement. The Ombudsman has advised Lead Class Counsel that it does not expect these costs to exceed $2 million. 1 The final piece of information that the Claims Administrator will require to prepare and file the Preliminary Final Accounting is the Court s determination of the amount of the Fee Award to Class Counsel. Pursuant to Section X.B of the Settlement Agreement, the fees to be awarded by the Court may not exceed 7.4% of the Fee Base (defined by Section II.O of the Settlement Agreement to be $1.25 billion minus $22.5 million i.e., $1,227,500,000. This means that the maximum potential fee award is $90,835,000. Based on the foregoing, the total of the Implementation Costs plus the Ombudsman Costs plus the maximum possible attorneys fees will not exceed $127,835,000. Subtracting this maximum amount from the $1.25 billion in Settlement Funds would leave $1,122,165,000 for the payment of awards to prevailing claimants under the Settlement Agreement. Since, as computed above, it is projected that the total amount of the Track A Liquidated Awards, Track A Loan Awards, and Track A Tax Awards for prevailing Class Members will not exceed $1,120,425,000. This means that it is highly likely that there will be sufficient Settlement Funds to pay all prevailing Class Members the full amount of the award authorized by the Settlement Agreement regardless of the actual Implementation Costs computed by the Claims Administrator or the amount of the attorneys fees awarded by the Court. As noted above, the Claims Administrator currently projects that by July 19 the final review process will be completed and it will be able to confirm the number of prevailing Track A claimants who will receive a Track A Loan Award and the amount of their awards. Based on 1 Section V.E.7 of the Settlement Agreement also requires the Claims Administrator to determine the amount of any interim Common Benefit Fees and the Track B Fees incurred by Track B Class Members. No interim Common Benefit Fees were sought or awarded. And because no Track B claimants were found to have satisfied the requirement for a Track B Award, no fees will be incurred by any Track B members. 4

this projection, the Claims Administrator expects to submit its Preliminary Final Accounting by July 26. And, based on this timetable, Lead Class Counsel expect to file the Motion for Approval for Distribution of Funds pursuant to Section IV.H of the Settlement Agreement by no later than July 31. Respectfully submitted, /s/ Henry Sanders Henry Sanders CHESTNUT, SANDERS, SANDERS, PETTAWAY & CAMPBELL, L.L.C. One Union Street Selma, AL 36701 Tel: (334 875-9264 Fax: (334 875-9853 /s/ Andrew H. Marks Andrew H. Marks D.C. Bar No. 932269 COFFEY BURLINGTON P.L. 2699 South Bayshore Drive Miami, FL 33133 Tel: (305 858-2900 Fax: (305 858-5261 /s/ Gregorio A. Francis Gregorio A. Francis MORGAN & MORGAN, P.A. 20 North Orange Avenue, Suite 1600 Orlando, FL 32801 Tel: (407 420-1414 Dated: July 8, 2013 CERTIFICATE OF SERVICE I certify that on July 8, 2013, I served a copy of the above on all counsel of record by filing a copy via the ECF system. /s/ Andrew H. Marks Andrew H. Marks 5