Important Dates
February 1, 2021 — Exclusion Deadline
February 1, 2021 — Objection Deadline
April 2, 2021 at 11:30 a.m. — Fairness Hearing
April 16, 2021 — Claim Form Deadline
By order dated March 18, 2021, the Court has decided to hold the April 2, 2021 Fairness Hearing by telephone only. Please do not try to attend in person. Please check the public docket or contact the Settlement Administrator for dial-in information.
Important Documents
Final Judgment (Bank of America)
Final Judgment (Deutsche Bank)
Order Awarding Attorneys’ Fees, Litigation Expenses, and Service Awards
Order Approving Plan of Allocation
[Proposed] Final Judgment (Bank of America)
[Proposed] Final Judgment (Deutsche Bank)
[Proposed] Final Judgment (HSBC)
[Proposed] Order Awarding Attorneys’ Fees, Litigation Expenses, and Service Awards
[Proposed] Order Approving Plan of Allocation
Motion for Attorneys' Fees, Litigation Expenses and Service Awards
- Memorandum of Law ISO Motion for Attorneys Fees, Litigation Expenses, and Service Awards
- Declaration of Daniel L. Brockett and David W. Mitchell ISO Motion for Final Approval of Three Settlements and Co-Lead Counsel’s Motion for Attorneys’ Fees, Litigation Expenses and Service Awards
- Declaration of Brian T. Fitzpatrick ISO Motion for Attorney Fees, Litigation Expenses, and Service Awards
- Declaration of David W. Mitchell ISO Motion for Attorney Fees, Litigation Expenses, and Service Awards
- Declaration of Daniel L. Brockett ISO Motion for Attorney Fees, Litigation Expenses, and Service
- Reply Memorandum of Law in support of Plaintiffs’ Motions (1) for Final Approval of Three Settlements, Final Approval of the Plan of Allocation, and for Certification of the Settlement Classes; and (2) for Attorneys’ Fees, Litigation Expenses, and Service Awards
Motion for Final Approval of Settlements
- Memorandum of Law ISO Motion for Final Approval of Three Settlements, Final Approval of the Plan of Allocation, and Certification of the Settlement Classes
- Declaration of Markham Sherwood Regarding Dissemination of Notice for Three Settlements
- Declaration of Jason Rabe regarding Mailing of Notice of Proposed Settlements of Class Action and Proof of Claim and Release Form
- Reply Memorandum of Law in support of Plaintiffs’ Motions (1) for Final Approval of Three Settlements, Final Approval of the Plan of Allocation, and for Certification of the Settlement Classes; and (2) for Attorneys’ Fees, Litigation Expenses, and Service Awards
- Supplemental Declaration of Markham Sherwood Regarding Dissemination of Notice for Three Settlements and Report on Opt-Outs and Objections Received
Notice of Proposed Settlements of Class Action
Second Consolidated Amended Complaint
Stipulation and Agreement of Settlement with Deutsche Bank AG and Deutsche Bank Securities
Stipulation and Agreement of Settlement with HSBC Securities (USA) Inc, and HSBC Bank PLC
Stipulation and Agreement of Settlement with Bank of America Corp
Order Providing for Notice and Preliminary Approval of Settlement