The Honorable Christopher M. Alston Chapter 0 0 In re Northwest Territorial Mint, LLC, Debtor, UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE I, Mary E. Olsen, declare as follows: Case No. --CMA SUPPLEMENTAL DECLARATION OF MARY E. OLSEN IN SUPPORT OF JOINT MOTION FOR AN ORDER () GRANTING CLASS CERTIFICATION FOR PURPOSES OF SETTLEMENT ONLY; () APPOINTING SETTLEMENT CLASS REPRESENTATIVE AND SETTLEMENT CLASS COUNSEL; () PRELIMINARILY APPROVING THE SETTLEMENT AGREEMENT BETWEEN CLASS CLAIMANT, ON HER OWN BEHALF AND ON BEHALF OF THE SETTLEMENT CLASS; () APPROVING THE FORM AND MANNER OF NOTICE TO SETTLEMENT CLASS; () SCHEDULING A FINAL FAIRNESS HEARING FOR THE FINAL CONSIDERATION AND APPROVAL OF THE SETTLEMENT; AND () FINALLY, APPROVING THE SETTLEMENT RELATED RELIEF - Case --CMA Doc Filed /0/ Ent. /0/ ::0 Pg. of
0 0. I am a member of The Gardner Firm, PC, one of the law firms appointed as Settlement Class Counsel for Brittany Konkel ( Class Claimant ) and the individuals on the attached Settlement Schedule ( Settlement Class Members ).. This declaration is submitted in further support of final approval of the Settlement Agreement (Dkt. No. - the Settlement Agreement ), as requested in the Parties Joint Motion For An Order () Granting Class Certification For Purposes Of Settlement Only; () Appointing Settlement Class Representative And Settlement Class Counsel; () Preliminarily Approving The Settlement Agreement Between Class Claimant, On Her Own Behalf And On Behalf Of The Settlement Class; () Approving The Form And Manner Of Notice To Settlement Class; () Scheduling A Final Fairness Hearing For The Final Consideration And Approval Of The Settlement; And () Finally, Approving The Settlement (Dkt. No. ). Motion.. On September, 0, the Court granted preliminary approval of the Joint. Settlement Class Counsel prepared the approved Class Notice and personalized Exhibit A to the Class Notice for each Settlement Class Member to reflect their projected allocation of the Settlement Amount, after the deduction of Settlement Class Counsel s Fees, Settlement Class Counsel s Expenses and the Service Payment.. On September, 0, Settlement Class Counsel mailed the Class Notice, which included the personalized Exhibit A and the opt-out form, to all Settlement Class Members.. Settlement Class Counsel used a $,000 expense total for purposes of calculating the personalized Settlement Class Member allocations used in Exhibit A to the September, 0 Class Notices. Settlement Class Counsel s expenses in this matter actually exceed $,000, but the Parties agreed in the Settlement Agreement that reimbursable expenses would be capped at that amount (Settlement Agreement, para. ). Settlement Class Counsel s expenses related to the RELATED RELIEF - Case --CMA Doc Filed /0/ Ent. /0/ ::0 Pg. of
0 mediation alone, totaled more than $,000 (i.e., $,0 to Schwabe Williamson & Wyatt (mediator s firm), plus expenses of $ related to attendance at the mediation, which total $). In addition to the mediation related expenses, Settlement Class Counsel incurred costs for legal research; copies; postage (relating to noticing) and PACER charges.. The attached Settlement Schedule reflects the $,000 expense deduction and includes the Settlement Class Member allocations which were used in Exhibit A to the personalized Class Notices mailed to Settlement Class Members on September, 0.. There were no opt-outs or objections to the Settlement.. The Parties agree that the attached, updated Settlement Schedule, containing the Settlement allocation amount reflected in each Settlement Class Member s September, 0 Class Notice, shall govern the Trustee s Settlement distributions in this matter. 0. In view of the foregoing and the Joint Motion, the Parties ask the Bankruptcy Court to enter an order for the relief requested in the Joint Motion, and to approve all aspects of the Settlement, including the use of the attached Settlement Schedule for purposes of the Trustee s Settlement distribution. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this declaration was executed on December, 0 in Mobile, 0 Alabama. /s/ Mary E. Olsen Mary E. Olsen RELATED RELIEF - Case --CMA Doc Filed /0/ Ent. /0/ ::0 Pg. of
CERTIFICATE OF SERVICE I certify that on this th day of December, 0, I caused the foregoing to be served via ECF to all parties who are listed on the Court s Electronic Mail Notice List. s/ Mary E. Olsen Mary E. Olsen 0 0 RELATED RELIEF - Case --CMA Doc Filed /0/ Ent. /0/ ::0 Pg. of
Northwest Territorial Mint Case: -CMA Allocation of Settlement As of September, 0 Settlement Amount $,000 Less: Promote Fee ($,000) Sub Total for Attorney Fee Calculation $,000 Less: Legal Fees ($0,) Less: Estimated Expenses ($,000) Net Allocation to Employee's $, # Employee Claim Allocation Adams, Steven G $, ($,) Adolf, Jason W $, ($) Alcantara, Luis $, ($) Alcantara, Rosa $, ($) Allen, Summer J $,00 ($) Baldassare, Jesse $, ($) Baldwin, Noelle $, ($,0) Barnard, Warren S $,00 ($,) Beasley, Susan K $,0 ($) 0 Bennett, Gary M $,0 ($) Blas, John P $, ($0) Bracamontes, Andrea $,0 ($) Braun, Danny L $, ($,0) Brunner, Jonathan $, ($) Burkard, Jeremy $, ($,0) Cacho-Bravo, Jorge $, ($) Carrasco, Eimy $,0 ($) Cazares, Maria T $, ($) Cedano, Norma $,0 ($) 0 Colwell, Martin J $, ($,) Davidson, Hallyma $,00 ($) Easley, Janet $, ($) Ebright, Stephen $, ($) Estrada, Irma C $, ($) Fall, Kimberly $,0 ($0) Fergus, William F $, ($) Fields, Jodi $, ($) Fleet, Jason $, ($) Foreman, Dale $, ($0) 0 Freeman, Roger $,0 ($,0) Goss, Wendy $,0 ($) Hauff, Cynthia A $,0 ($) Case --CMA Doc - Filed /0/ Ent. /0/ ::0 Pg. of
# Employee Claim Allocation Hook, James $,0 ($) Jacobs, Erica A $, ($) Jarrett, Nicole $, ($) Johns, Nathan $,00 ($) Johnson, Alan B $,0 ($) Johnson, Brenda L $,0 ($) Jones, Janette $,0 ($) 0 Jones, Laura A $, ($,) Jones, Randy W $0,0 ($,) Kenney, William B $, ($,) Knight, Dane $, ($) Knight, William B $,0 ($) Konkel, Brittany Storm $,0 ($) Lord, Chris $, ($,) Lozano, Alma $, ($) Madderra, Bobbi C $,0 ($) Mayer, Stephen $, ($) 0 Maynard, Leslie $,0 ($) McVeigh, Mark A $,0 ($,) Meinert, Gary H $, ($,0) Melendez, Lesley $, ($) Mena, Gloria $, ($) Meyers, Todd M $, ($,) Millim, Lisa A $,0 ($) Montes, Margarita $,0 ($) Moore, Weyna D.G. $, ($) Morris, Patricia A $,0 ($) 0 Munguia, Marisol $, ($0) O'Connell, Kelly $,0 ($) Palsgrove, Katherine A $, ($) Pedro, Cynthia $, ($) Pernoll, Irina S $, ($,0) Perry, Jessica $,00 ($) Platt, Elizabeth $,0 ($) Proctor, Ashlee $,00 ($) Rainey, Alyssa $, ($) Ramirez, Blanca $, ($) 0 Rayner, Deborah $, ($) Robinson, Donna L $, ($) Rodriguez, Juan $, ($) Rojas, Rafael $, ($) Ronk, Wesley $, ($) Rosales, Antonio $,0 ($) Case --CMA Doc - Filed /0/ Ent. /0/ ::0 Pg. of
# Employee Claim Allocation Saenz, Ana $, ($0) Scott, Kathy $, ($) Semler, Mitchell $,00 ($) Serpa, Lindsey $, ($) 0 Sharp, Jeremy $,0 ($) Shear, Erin $, ($,0) Swinburg, Cathy $, ($) Thompson, David $,0 ($) Tirri, Christopher $, ($) Villegas, Alma R $,00 ($) Waldrep, Bobby L $,00 ($) Webb, Christopher $,0 ($) White, Michael $, ($,0) Williams, Jeremiah $, ($) 0 Williams, Nicole $, ($0) Wilson III, Richard L $, ($,) Zepeda, Monica Y $,0 ($) Employee's Terminated After / Alves, Zachary J $ ($) Davis, Debra S $, ($) Fleet, Kathyjean $ ($) Hooper, Nicole $ ($0) Lee, Matthew $, ($) Leffler, Travis $, ($) Timm, Dennis $, ($0) 00 Webb, Alisha $, ($) $, ($,) Case --CMA Doc - Filed /0/ Ent. /0/ ::0 Pg. of