Important Case Documents

Class Action Complaint

• Second Amended Complaint

Settlement Documents

• Class Notice
• Order Preliminarily Approving Class Action Settlement, Preliminarily Certifying Settlement Class, Approving Procedure and Form of Notice, and Scheduling Fairness Hearing
• Class Action Settlement Agreement
• Former Participant Rollover Form
• Plaintiffs’ Notice of Motion for Attorneys’ Fees, Expenses, and Class Representative Service Awards
• Memorandum in Support of Plaintiffs’ Motion for Attorneys’ Fees, Expenses, and Class Representative Service Awards
• [Proposed] Order on Plaintiffs’ Motion for Attorneys’ Fees, Expenses, and Class Representative Service Awards
• Plaintiffs’ Notice of Motion for Preliminary Approval of Class Action Settlement
• Memorandum of Law in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Plaintiffs’ Notice of Motion for Final Approval of Class Action Settlement
• Memorandum of Law in Support of Plaintiffs’ Motion for Final Approval of Class Action Settlement
• [Proposed] Order Granting Plaintiffs’ Motion for Final Approval of Class Action Settlement
• Richter Letter Regarding Objection
  • Exh 1: Marsh Objection
  • Exh 2: Complaint and Jury Demand

Declarations

• Declaration of Kai Richter in Support Of Plaintiffs’ Motion for Attorneys’ Fees, Expenses, and Class
• Declaration of Kai Richter in Support of Plaintiffs’ Motion for Preliminary Approval Of Class Action Settlement
• Declaration of Wayne Antoine in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Joseph Bendrihem in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Larry Gilbert in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Claudia Gonzalez in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Thomas Lantz in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Amy Laurence in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Anthony Medici in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Rafael Musni in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Sandra Scanni in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Lee Webber in Support of Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
• Declaration of Jeffrey Mitchell in Support of Plaintiffs’ Motion for Final Approval of Class Action Settlement
  • Exhibit 1: Class Notice
  • Exhibit 2: Former Participant Rollover Form
• Declaration of Kai Richter in Support of Plaintiffs’ Motion for Final Approval of Class Action Settlement
  • Exh A: Re: Statement of Independent Fiduciary – Settlement of Krohnengold v. New York Life Insurance Company et al, Docket No. 1:21-cv-01778 (S.D.N.Y. Mar 02, 2021)