Common use of PLAN FOR RESPONSE TO OBJECTIONS AND REQUESTS FOR INFORMATION Clause in Contracts

PLAN FOR RESPONSE TO OBJECTIONS AND REQUESTS FOR INFORMATION. 1. Class counsel will set up (a) a toll-free telephone number to accept messages, (b) a post office box (or other mailing address) to which letters from IHSS recipients may be sent and (c) an email address for IHSS recipients to make inquires and request additional information about the settlement. These options for communicating with Class counsel will be described in the Class notice and available during the period for submitting objections and for one week after the date of the fairness hearing. Class counsel will review and log all communications from IHSS recipients. 2. In responding to communications from IHSS recipients, Class counsel will first identify objections, which will be logged and shared with counsel for Defendants. At the close of the objection period, the parties will confer, categorize the objections and provide the Court with a joint report summarizing all objections. Counsel will also respond to objections after the deadline by informing them that the time period has ended but providing additional information if requested. 3. Class counsel will next identify requests for additional information. These will also be logged and provided with an appropriate response, which might be to provide a copy of the notice in alternative languages or formats, to mail the settlement agreement, or to answer any specific questions that are not addressed in the Settlement materials. Class counsel will maintain a log of these inquiries and the response provided and will be prepared to provide this to the court in camera if requested. 4. Class counsel will next identify complaints and questions that are unrelated to the settlement. If these relate to areas in which Class counsel can provide assistance, the inquiry will be referred to intake staff for the respective program. If it is not an area in which class counsel can assist, the individual will be sent a communication (telephone call, letter or email), stating that Class counsel cannot assist and, if possible, offering a referral to other assistance such as the county bar association or the local legal aid program. Class counsel will maintain a log of these inquiries and the response provided and will be prepared to provide this to the court in camera if requested. 4 5 6 7 8 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 9 SAN FRANCISCO/OAKLAND DIVISION 10 XXXXX XXXXX, et al., ) 11 ) 13 v. ) 14 WILL LIGHTBOURNE, Director of the ) California Department of Social Services; ) 15 XXXX XXXXXXX, Director of the California ) Department of Health Care Services; ) Case No.: CV 09-04668 CW Date: Time: Courtroom: 16 CALIFORNIA DEPARTMENT OF HEALTH ) 19 20 21 Plaintiffs XXXXX XXXXX, XXXXXX XXXXXXXX XXXXXXXX, C.R. by and through his 22 guardian ad litem M.R., XXXXXX XXXXX, XXXXXX XXXXXX, XXXXX XXXXX XXXXX, 23 XXXXXXX XXXXXXX, and X.X. by and through her guardian ad litem M.G. (collectively 24 “Named Plaintiffs”) have filed, and all parties support, a Motion for Final Approval of Class 25 Settlement (“Motion for Final Approval”). The Class Settlement Agreement, entered into by 26 Named Plaintiffs, Union Plaintiffs (Service Employees International Union-United Healthcare 27 Workers, Service Employees International Union-United Long Term Care Workers, Service 1 Employees International Union Local 521, Service Employees International Union California 2 State Council, United Domestic Workers of America, AFSCME Local 3930, AFL-CIO, and 3 California United Homecare Workers), and Defendants, is attached to this order as Exhibit 1. 4 Classes and subclasses in this case have previously been certified under Federal Rule of

PLAN FOR RESPONSE TO OBJECTIONS AND REQUESTS FOR INFORMATION. 1. Class counsel will set up (a) a toll-free telephone number to accept messages, (b) a post office box (or other mailing address) to which letters from IHSS recipients may be sent and (c) an email address for IHSS recipients to make inquires and request additional information about the settlement. These options for communicating with Class counsel will be described in the Class notice and available during the period for submitting objections and for one week after the date of the fairness hearing. Class counsel will review and log all communications from IHSS recipients. 2. In responding to communications from IHSS recipients, Class counsel will first identify objections, which will be logged and shared with counsel for Defendants. At the close of the objection period, the parties will confer, categorize the objections and provide the Court with a joint report summarizing all objections. Counsel will also respond to objections after the deadline by informing them that the time period has ended but providing additional information if requested. 3. Class counsel will next identify requests for additional information. These will also be logged and provided with an appropriate response, which might be to provide a copy of the notice in alternative languages or formats, to mail the settlement agreement, or to answer any specific questions that are not addressed in the Settlement materials. Class counsel will maintain a log of these inquiries and the response provided and will be prepared to provide this to the court in camera if requested. 4. Class counsel will next identify complaints and questions that are unrelated to the settlement. If these relate to areas in which Class counsel can provide assistance, the inquiry will be referred to intake staff for the respective program. If it is not an area in which class counsel can assist, the individual will be sent a communication (telephone call, letter or email), stating that Class counsel cannot assist and, if possible, offering a referral to other assistance such as the county bar association or the local legal aid program. Class counsel will maintain a log of these inquiries and the response provided and will be prepared to provide this to the court in camera if requested. 4 5 6 7 8 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA 9 SAN FRANCISCO/OAKLAND DIVISION 10 XXXXX XXXXXXXXXXXXXX, et al., Plaintiffs, v. WILL LIGHTBOURNE, et al., ) 11 ) 13 v. ) 14 WILL LIGHTBOURNE, Director of the ) California Department of Social Services; ) 15 XXXX XXXXXXX, Director of the California ) Department of Health Care Services; ) ) ) ) ) Case No.: CV C 09-04668 02306 CW [PROPOSED] ORDER GRANTING FINAL APPROVAL OF CLASS SETTLEMENT Date: Time: Courtroom: 10 11 14 15 16 CALIFORNIA DEPARTMENT OF HEALTH ) 19 20 21 17 18 Plaintiffs XXXXX XXXXXX, XXXX XXXXX, by and through his mother and next friend 19 Xxxx Xxxxx, XXXXX XXXXX, XXXXX XXXXXX, by and through her conservator and next 20 friend Xxxxx Xxxxxxxx-Xxxxxxxxxx, XXXXXXX X. XXXXX, XXXXXX XXXXXX, XXXXXXXX 21 XXXXX, XXXXXX XXXXXXXX XXXXXXXX, C.R. by and through his 22 guardian ad litem M.R., XXXXXX XXXXX, XXXXXX XXXXXX, XXXXX XXXXX XXXXX, 23 XXXXXXX XXXXXXXXXXX XXXXXXXX, and X.X. by and through her guardian ad litem M.G. XXXXXXX XXXXXXX 22 (collectively 24 “Named Plaintiffs”) have filed, and all parties State Defendants (Will Lightbourne and Xxxx 23 Xxxxxxx) support, a Motion for Final Approval of Class 25 Settlement (“Motion for Final Approval”). 24 The Class Settlement Agreement, entered into by 26 Named Plaintiffs, Union Plaintiffs (Service 25 Employees International Union-United Healthcare 27 Workers, Service Employees International 26 Union-United Long Term Care Workers, Service 1 Employees International Union Local 521, 27 Service Employees International Union California 2 State Council, United Domestic Workers of 1 America, AFSCME Local 3930, AFL-CIO, and 3 California United Homecare Workers), and State 2 Defendants, is attached to this order as Exhibit 1. 4 3 Classes and subclasses in this case have previously been certified under Federal Rule of