Case: Unknown Party v. Motel 6

2:18-cv-00242 | U.S. District Court for the District of Arizona

Filed Date: Jan. 23, 2018

Case Ongoing

Clearinghouse coding complete

Case Summary

This case challenged the hotel chain Motel 6 reporting guests to federal immigration officials. Eight individuals who stayed separately at Arizona Motel 6 locations filed a class action lawsuit in U.S. District Court for the District of Arizona on January 23, 2018. Suing under 42 U.S.C. § 1983, plaintiffs sued Motel 6 Operating L.P., its parent company G6 Hospitality LLC, and 10 unnamed Motel 6 employees in Arizona. The plaintiffs, represented by the Mexican American Legal Defense and Education…

This case challenged the hotel chain Motel 6 reporting guests to federal immigration officials.

Eight individuals who stayed separately at Arizona Motel 6 locations filed a class action lawsuit in U.S. District Court for the District of Arizona on January 23, 2018. Suing under 42 U.S.C. § 1983, plaintiffs sued Motel 6 Operating L.P., its parent company G6 Hospitality LLC, and 10 unnamed Motel 6 employees in Arizona. The plaintiffs, represented by the Mexican American Legal Defense and Educational Fund (MALDEF), requested class certification, and sought declaratory, monetary, and injunctive relief, as well as a civil penalty and attorneys' fees and costs. Judge David G. Campbell was assigned.

Plaintiffs claimed Motel 6's policy of disclosing guests' information to the U.S. Department of Homeland Security (DHS) and U.S. Immigration and Customs Enforcement (ICE) without requiring a warrant or reasonable suspicion of criminal activity violated the Fourth Amendment, as well as federal and state laws. Defendants allegedly violated 42 U.S.C. § 1981 by discriminating against plaintiff’s race or national origin by denying Latino guests the full and equal enjoyment of the contractual relationship with Motel 6. Additionally, by assisting DHS and ICE agents, the plaintiffs alleged that Motel 6 violated 42 U.S.C. § 1985(3) by engaging in a conspiracy to violate the plaintiff's rights. Thirdly, the plaintiffs alleged that the defendants violated their Fourth Amendment right to be free from unreasonable searches and seizures by disclosing the plaintiffs' personal information to federal immigration officials without a warrant or reasonable suspicion of a crime. The plaintiffs also alleged a variety of state law violations, including various tort and breach of contract claims.

The parties filed a joint notice of settlement on July 6, 2018. A joint request for conditional class certification and preliminary approval of settlement terms was filed on July 6, 2018.

Plaintiffs sought one primary class and two subclasses. The primary class consisted of all persons who stayed at a Motel 6 between February 1, 2017, and November 2, 2018, and had their information shared with federal immigration authorities. The first subclass was all persons who were questioned or interrogated by federal immigration authorities at a Motel 6 as a result of guest information being shared. The second subclass was for all persons who had been placed in immigration removal proceedings due to disclosed guest information and the resulting encounters with federal immigration authorities at a Motel 6.

The proposed settlement included a two-year enforcement period under a consent decree that would enjoin Motel 6 from providing guest information to DHS and ICE absent a warrant, subpoena, or the immediate risk of harm to a guest, employee, or another individual. Additionally, parties sought three categories of monetary damages totaling $7.6 million. First, $50 in damages per guest whose information was shared with federal immigration authorities, up to a class-wide total of $1,000,000. Second, $1,000 in damages to each class member questioned by federal immigration authorities during their stay. Finally, an amount of at least $7,500 to each Class Member who was placed in immigration removal proceedings in connection with their encounter with federal immigration authorities during their stay.

On May 30, 2019, the court mooted the parties' joint motion. The parties had advised the court that they would be filing a new motion for preliminary approval of a class settlement.

Plaintiffs filed an amended class-action complaint on June 5, 2019. The amended complaint contains largely the same allegations and claims as in the original complaint. Plaintiffs now sought a primary class and one subclass. The primary class was all persons who stayed at a Motel 6 and had their information disclosed to federal immigration authorities between February 1, 2015, and the date of judgment in the present case. The subclass included guests at a Motel 6 that had been interrogated, arrested, or placed in removal proceedings by federal immigration authorities due to guest information being disclosed.

The parties again filed a joint motion for approval of the class action settlement and to certify class on July 5, 2019. The court granted preliminary approval of the class action settlement on August 2, 2019.

On January 17, 2020, the parties filed a joint motion requesting five actions. First, final approval of the settlement. Second, certification of the proposed classes. Third, a consent decree for injunctive relief. Fourth, authorization to distribute the settlement monetary damages in accordance with the agreement. Finally, payment of attorneys’ fees and costs.

The court granted final approval of the third amended class action settlement on February 18, 2020. The court found that the amount of funds going to class members was sufficient and that the amount of funds held for four immigration rights organizations was "consistent with the underlying objectives of the claims in this case, serves the interests of the silent class members, and is not too remote from the class."

Judge Campbell signed a consent decree on February 18, 2020, making effective injunctive and recordkeeping provisions for three years. The injunctive provisions mandated Motel 6 do the following:

  • Maintain a 24-hour hotline for employee use when they receive a federal request for guest information.
  • Not share any guest information with federal immigration authorities without a warrant, subpoena, or credible risk of imminent danger.
  • Motel 6 to create an online form for guests to report if guest information was improperly shared.
  • Maintain documentation related to reporting.
  • Annual meeting with parties to ensure compliance with consent decree.
The parties attended the first required annual meetings on March 4, 2021. According to a joint status report filed on March 29, 2021, Motel 6 had complied with the consent decree. The aforementioned 24-hour hotline, online reporting system, and policies have all been implemented. Motel 6 has explicitly required that franchise locations also adopt the above requirements.

The court retains jurisdiction over the matter for the duration of the consent decree.

Summary Authors

Lisa Koo (1/30/2019)

Aaron Gurley (3/5/2020)

Eric Gripp (7/20/2021)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/6285327/parties/unknown-party-v-motel-6-operating-lp/


Judge(s)

Campbell, David G. (Arizona)

Attorneys(s) for Plaintiff

Gallegos, Andres J (California)

Holguin, Andres R (California)

Ortega, Daniel R. Jr. (Arizona)

Perales, Nina (Texas)

Saenz, Thomas A. (California)

Attorneys(s) for Defendant

Bivens, Donald W (Arizona)

DeSanctis, Michael B (District of Columbia)

Kadzik, Peter J (District of Columbia)

Lynch, Christopher M (District of Columbia)

Judge(s)

Campbell, David G. (Arizona)

Attorneys(s) for Plaintiff

Gallegos, Andres J (California)

Holguin, Andres R (California)

Ortega, Daniel R. Jr. (Arizona)

Perales, Nina (Texas)

Saenz, Thomas A. (California)

Attorneys(s) for Defendant

Bivens, Donald W (Arizona)

DeSanctis, Michael B (District of Columbia)

Kadzik, Peter J (District of Columbia)

Lynch, Christopher M (District of Columbia)

Refo, Patricia Lee (Arizona)

Tobin, Stacie E. (Maryland)

Verrilli, Donald B. Jr. (District of Columbia)

Other Attorney(s)

Crandell, Rusty D. (Arizona)

Jessen, Katherine H. (Arizona)

Sawyer, Kate B. (Arizona)

Skinner, Oramel Horace (Arizona)

Vogel, Dana Rae (Arizona)

Documents in the Clearinghouse

Document

Docket

March 29, 2021 Docket
34

Order/Opinion

Nov. 2, 2018 Order/Opinion
1

Complaint

Jan. 14, 2019 Complaint
87

Order

Feb. 18, 2020 Order/Opinion
88

Consent Decree

Feb. 18, 2020 Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/6285327/unknown-party-v-motel-6-operating-lp/

Last updated May 11, 2022, 8 p.m.

ECF Number Description Date Link
1

CLASS ACTION COMPLAINT. Filing fee received: $ 400.00, receipt number 0970-15085270 filed by Unknown Party (named as John M.; individually and on behalf of all others similarly situated), Unknown Party (named as John A.; individually and on behalf of all others similarly situated), Unknown Party (named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party (named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party (named as John E.; individually and on behalf of all others similarly situated), Unknown Party (named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party (named as John W.; individually and on behalf of all others similarly situated), Unknown Party (named as John D.; individually and on behalf of all others similarly situated). (Submitted by Nina Perales) (Attachments: # 1 Civil Cover Sheet)(LAD) (Entered: 01/24/2018)

1 Civil Cover Sheet

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Jan. 23, 2018 RECAP
2

NOTICE TO THE PARTIES - The Court is participating in the Mandatory Initial Discovery Pilot (MIDP) and this case is subject to that pilot. The key features and deadlines are set forth in the attached Notice which includes General Order 17-08. Also attached is a checklist for use by the parties. All parties must respond to the mandatory initial discovery requests set forth in the General Order before initiating any further discovery in this case. Please note: The discovery obligations in the General Order supersede the disclosures required by Rule 26(a)(1). Any party seeking affirmative relief must serve a copy of the attached documents (Notice to Parties, including General Order 17-08 and MIDP Checklist) on each new party when the Complaint, Counterclaim, Crossclaim, or Third-Party Complaint is served. (LAD) (Entered: 01/24/2018)

Jan. 23, 2018 RECAP
3

Filing fee paid, receipt number 0970-15085270. This case has been assigned to the Honorable Deborah M Fine. All future pleadings or documents should bear the correct case number: CV-18-00242-PHX-DMF. Magistrate Election form attached. (Attachments: # 1 Instructions) (LAD) (Entered: 01/24/2018)

1 Instructions

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Jan. 23, 2018 PACER

Remark: Pro hac vice motion granted for Nina Perales on behalf of plaintiffs. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Jan. 24, 2018 PACER
4

Ordered that Jane V., John A., John E., Jane F., John D., John M., Jane N., and John W. show cause for failure to comply with LRCiv 3.7(b) before Judge G Murray Snow. Show Cause Hearing set for 3/12/2018 at 04:30 PM before Judge G Murray Snow. (Attachments: # 1 Instructions, # 2 Consetn Form)(MAP) (Entered: 02/09/2018)

1 Instructions

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2 Consetn Form

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Feb. 9, 2018 RECAP

Remark: Pro hac vice motions granted for Andres R Holguin-Flores and Andres J Gallegos on behalf of plaintiffs. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Feb. 12, 2018 PACER
6

Agreement to Magistrate Judge Jurisdiction. Party agrees to Magistrate Judge Jurisdiction. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MAP) (Entered: 02/13/2018)

Feb. 12, 2018 PACER
7

MINUTE ORDER: That counsel having complied with this Court's Order, the Order to Show Cause Hearing scheduled for March 12, 2018 is hereby VACATED. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MAP) (Entered: 02/13/2018)

Feb. 13, 2018 PACER
8

SUMMONS Submitted by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Gallegos, Andres) (Entered: 02/14/2018)

Feb. 14, 2018 RECAP

Remark: Pro hac vice motion granted for Thomas Saenz on behalf of plaintiffs. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

March 5, 2018 PACER
9

NOTICE TO FILER OF DEFICIENCY re: 8 Summons Submitted filed by Unknown Party. Summons completed incorrectly. FOLLOW-UP ACTION REQUIRED: Please refile corrected summonses listing only one Defendant per summons using the Service of Process / Summons Submitted category. As soon as the Court receives the corrected summons, they will be issued on the following business day. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DXD) (Entered: 03/05/2018)

March 5, 2018 PACER
10

SUMMONS Submitted by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Gallegos, Andres) (Entered: 03/06/2018)

March 6, 2018 PACER
11

SUMMONS Submitted by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Gallegos, Andres) (Entered: 03/06/2018)

March 6, 2018 PACER
12

Summons Issued as to G6 Hospitality LLC, Motel 6 Operating LP. (Attachments: # 1 Summons)(BAS). *** IMPORTANT: When printing the summons, select "Document and stamps" or "Document and comments" for the seal to appear on the document. (Entered: 03/06/2018)

1 Summons

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March 6, 2018 PACER
13

SERVICE EXECUTED filed by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated): Rule 4 Waiver of Service of Summons. Waiver sent on 3/8/2018 to G6 Hospitality, LLC . (Gallegos, Andres) (Entered: 03/16/2018)

March 16, 2018 PACER
14

ORDER SETTING RULE 16 CASE MANAGEMENT CONFERENCE - Pursuant to Rule 16 of the Federal Rules of Civil Procedure, a telephonic Case Management Conference is set for Monday, June 11, 2018 at 2:30 pm. The Court has set aside one hour for the telephonic conference. (See document for complete details). Signed by Magistrate Judge Charles R Pyle on 3/26/18. (SLQ) (Entered: 03/26/2018)

March 26, 2018 PACER
15

NOTICE of Appearance by Patricia Lee Refo on behalf of G6 Hospitality LLC, Motel 6 Operating LP. (Refo, Patricia) (Entered: 03/26/2018)

March 26, 2018 PACER
17

Party Elects Assignment of Case to District Judge Jurisdiction. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MAP) (Entered: 03/27/2018)

March 26, 2018 PACER
18

MINUTE ORDER: Pursuant to Local Rule 3.7(b), a request has been received for a random reassignment of this case to a District Judge. FURTHER ORDERED Case reassigned by random draw to Judge David G. Campbell. All further pleadings/papers should now list the following COMPLETE case number: CV-18-242-PHX-DGC. IT IS FURTHER ORDERED that the Scheduling Conference set before Judge Charles R. Pyle on 6/11/18 at 2:30 PM is now RESET before Judge David G. Campbell, unless otherwise ordered by the Court. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MAP) (Entered: 03/27/2018)

March 27, 2018 PACER
19

ORDER re: 18 Minute Order, Add and Terminate Judges, Set/Reset Hearings. The Rule 16 Case Management Conference set before The Honorable Charles Pyle for 6/11/2018 at 2:30 PM is VACATED and RESET for 6/15/2018 at 03:30 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Judge David G Campbell. Signed by Judge David G Campbell on 4/4/2018. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 04/04/2018)

April 4, 2018 PACER
20

SERVICE EXECUTED filed by Unknown Party(named as John M.; individually and on behalf of all others similarly situated): Proof of Service re: Summons & Complaint upon Motel 6 Operating LP on 03/27/2018. (Ortega, Daniel) (Entered: 04/06/2018)

April 6, 2018 PACER
21

STIPULATION FOR EXTENSION OF TIME TO ANSWER COMPLAINT by G6 Hospitality LLC, Motel 6 Operating LP. (Attachments: # 1 Text of Proposed Order Proposed Order)(Refo, Patricia) (Entered: 04/11/2018)

1 Text of Proposed Order Proposed Order

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April 11, 2018 PACER
22

ORDER granting a one-time extension of time until 5/8/2018 for Defendants Motel 6 Operating, LP and G6 Hospitality LLC to respond to complaint. The parties' obligations to produce the information called for in the MIDP will be triggered by Defendant's answer to the complaint after the extension. The parties should be aware that the filing of a motion to dismiss under Rule 12(b)(6) will not postpone the time for compliance with the MIDP. General Order 17-08 provides that compliance may be deferred only for motions to dismiss based on lack of subject-matter jurisdiction, lack of personal jurisdiction, sovereign immunity, or absolute or qualified immunity of a public official. No further extensions will be granted. Signed by Judge David G Campbell on 4/11/2018. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 04/11/2018)

April 11, 2018 PACER
23

ANSWER to Complaint by G6 Hospitality LLC, Motel 6 Operating LP. (Attachments: # 1 Exhibit Exhibit A)(Refo, Patricia) (Entered: 05/08/2018)

1 Exhibit Exhibit A

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May 8, 2018 RECAP
24

MOTION to Continue Defer Scheduling Conference by G6 Hospitality LLC, Motel 6 Operating LP, Unknown Parties. (Refo, Patricia) (Entered: 05/25/2018)

May 25, 2018 PACER
25

ORDER - All parties have indicated that they have a good faith belief that this case will be resolved within 30 days. Therefore, the time to submit MID responses is extended for 30 days. Absolutely no further extensions will be granted. The Rule 16 Case Management Conference set for 6/15/2018 at 3:30 PM is VACATED and RESET for 7/26/2018 at 04:30 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Judge David G Campbell. Signed by Judge David G Campbell on 5/29/2018. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 05/29/2018)

May 29, 2018 PACER
26

NOTICE of Settlement Joint Notice of Settlement and Joint Motion for Relief From All Pending Deadlines by G6 Hospitality LLC, Motel 6 Operating LP. (Attachments: # 1 Text of Proposed Order)(Refo, Patricia) (Entered: 07/06/2018)

1 Text of Proposed Order

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July 6, 2018 RECAP
27

NOTICE of Attorney Withdrawal Andres Gallegos filed by Andres J Gallegos. (Gallegos, Andres) (Entered: 07/06/2018)

July 6, 2018 PACER
28

***VACATED BY 30 ORDER*** ORDER - IT IS ORDERED: 1. This matter will, without further Order of this Court, be dismissed with prejudice on August 31, 2018 unless a stipulation to dismiss is filed prior to the dismissal date. 2. All pending hearings and deadlines are vacated. 3. All pending motions are found to be moot. 4. The Clerk is directed to terminate this matter on August 31, 2018 without further leave of Court if a stipulation to dismiss is not filed prior to this date. Signed by Judge David G Campbell on 7/6/18. (SLQ) Modified on 8/20/2018 (MSA). (Entered: 07/06/2018)

July 6, 2018 RECAP
29

Joint MOTION Entry of Scheduling Order and Relief from Deadlines in July 6, 2018 Order re: 28 Order, Terminate Deadlines and Hearings, Terminate Motions, Set Deadlines by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Attachments: # 1 Text of Proposed Order [Proposed])(Holguin-Flores, Andres) (Entered: 08/16/2018)

1 Text of Proposed Order [Proposed]

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Aug. 16, 2018 PACER
30

ORDER granting 29 Motion for Scheduling Order. The Courts 28 Order is vacated. The Parties shall file a joint motion seeking preliminary approval of the class settlement and any related filings no later than October 5, 2018. Signed by Senior Judge David G Campbell on 8/20/18. (MSA) (Entered: 08/20/2018)

Aug. 20, 2018 RECAP
31

Joint MOTION for Extension of Time To File Joint Motion for Preliminary Approval of Class-wide Settlement by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Attachments: # 1 Text of Proposed Order [Proposed] Order)(Holguin-Flores, Andres) (Entered: 10/04/2018)

1 Text of Proposed Order [Proposed] Order

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Oct. 4, 2018 PACER
32

ORDER - IT IS ORDERED that the consent joint motion for extension (Doc. 31 ) is granted. The parties shall file a joint motion seeking preliminary approval of the class settlement and any related filings no later than November 2, 2018. Signed by Senior Judge David G Campbell on 10/9/18. (SLQ) (Entered: 10/09/2018)

Oct. 9, 2018 PACER
33

*Joint MOTION to Certify Class, Joint MOTION ( 1) Granting Preliminary Approval of the Class Action Settlement; (2) Conditionally Certifying Settlement Class; (3) Appointing Class Representatives and Class Counsel; (4) Approving Notice Plan; and (5) Setting Final Approval Hearing by Unknown Party (named as John M.), Unknown Party (named as John A.), Unknown Party (named as Jane F.), Unknown Party (named as Jane N.), Unknown Party (named as John E.), Unknown Party (named as Jane V.), Unknown Party (named as John W.), Unknown Party (named as John D.). (Attachments: # 1 Exhibit Proposed Settlement Agreement, # 2 Declaration of Andres Holguin-Flores, # 3 Exhibit Proposed Claim Form, # 4 Exhibit Proposed Postcard Notice, # 5 Exhibit Proposed Website Notice, # 6 Exhibit Proposed Social Media Notice, # 7 Text of Proposed Order)(Holguin-Flores, Andres) *Modified text on 11/5/2018 (ATD). (Entered: 11/02/2018)

1 Exhibit Proposed Settlement Agreement

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2 Affidavit Declaration of Andres Holguin-Flores

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3 Exhibit Proposed Claim Form

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4 Exhibit Proposed Postcard Notice

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5 Exhibit Proposed Website Notice

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6 Exhibit Proposed Social Media Notice

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7 Text of Proposed Order

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Nov. 2, 2018 RECAP
34

*NOTICE of Errata re: 33 Joint MOTION to Certify Class, Joint MOTION (1) Granting Preliminary Approval of the Class Action Settlement; (2) Conditionally Certifying Settlement Class; (3) Appointing Class Representatives and Class Counsel; (4) Approving Notice Plan; and (5) Setting Final Approval Hearing Corrected Proposed Order by Plaintiffs Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party. (Attachments: # 1 Text of Proposed Order Correct Proposed Order)(Holguin-Flores, Andres) *Modified text on 11/5/2018 (ATD). (Entered: 11/02/2018)

1 Text of Proposed Order Correct Proposed Order

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Nov. 2, 2018 PACER
35

*Joint NOTICE of Request for Oral Argument by Motel 6 Operating LP, G6 Hospitality LLC . (Refo, Patricia) *Modified text and to add filer on 11/6/2018 (ATD). (Entered: 11/05/2018)

Nov. 5, 2018 RECAP

Remark: Pro hac vice motions granted for Michael DeSanctis, Christopher M Lynch and Donald Verrilli Jr on behalf of defendants. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Nov. 7, 2018 PACER

Remark: Pro hac vice motion granted for Peter J Kadzik on behalf of defendants. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Nov. 20, 2018 PACER
36

ORDER, Hearing set as to 33 Joint MOTION to Certify Class, Joint MOTION (1) Granting Preliminary Approval of the Class Action Settlement; (2) Conditionally Certifying Settlement Class; (3) Appointing Class Representatives and Class Counsel; (4) Approving Notice Plan; and (5) Setting Final Approval Hearing: Motion Hearing set for 1/29/2019 at 02:00 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell. Signed by Senior Judge David G Campbell on 1/7/2019. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 01/07/2019)

Jan. 7, 2019 PACER
37

MINUTE ENTRY for proceedings held before Senior Judge David G Campbell: Hearing re: 33 Joint Motion to Certify Class held on 1/29/2019. The Court places its concerns on the record regarding the parties' submissions to the Court. The parties agree the issues would be best addressed in writing through supplemental filings. Supplemental filings are due 3/29/2019. Today's hearing is reset to 4/16/2019 at 2:00 PM in Courtroom 603. The parties inform the Court they will order the transcript of today's hearing to ensure each issue is addressed. APPEARANCES: Andres Holguin-Flores, Thomas Saenz, and Daniel Ortega, Jr. for Plaintiffs. Michael DeSanctis, Patricia Refo, Christopher Lynch for Defendants. (Court Reporter Patricia Lyons.) Hearing held 2:04 PM-2:26 PM and 2:34 PM-2:46 PM This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (CLB) (Entered: 01/29/2019)

Jan. 29, 2019 PACER
38

TRANSCRIPT REQUEST by G6 Hospitality LLC, Motel 6 Operating LP, Unknown Parties for proceedings held on 1/29/2019, Judge David G Campbell hearing judge(s). (Refo, Patricia) (Entered: 01/29/2019)

Jan. 29, 2019 PACER
39

ORDER re: Motion Hearing set for 4/16/2019 at 02:00 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell.Re: 33 Joint MOTION to Certify ClassJoint MOTION (1) Granting Preliminary Approval of the Class Action Settlement; (2) Conditionally Certifying Settlement Class; (3) Appointing Class Representatives and Class Counsel; (4) Approving Notice Plan; and (5) Setting Final Approval Hearing < filed by Unknown Party, Hearing set as to 33 Joint MOTION to Certify ClassJoint MOTION (1) Granting Preliminary Approval of the Class Action Settlement; (2) Conditionally Certifying Settlement Class; (3) Appointing Class Representatives and Class Counsel; (4) Approving Notice Plan; and (5) Setting Final Approval Hearing. Signed by Senior Judge David G Campbell on 1/30/2019. (DGC, nvo) (Entered: 01/30/2019)

Jan. 30, 2019 PACER
41

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of MOTIONS HEARING proceedings held on 01/29/2019, before Judge DAVID G. CAMPBELL. [Court Reporter: Patricia Lyons, RMR, CRR, Telephone number (602) 322-7257]. The ordering party will have electronic access to the transcript immediately. All others may view the transcript at the court public terminal or it may be purchased through the Court Reporter/Transcriber by filing a Transcript Order Form on the docket before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 2/20/2019. Redacted Transcript Deadline set for 3/4/2019. Release of Transcript Restriction set for 4/30/2019. (RAP) (Entered: 02/08/2019)

Jan. 30, 2019 PACER
40

ORDER. DUE TO A CONFLICT IN THE COURT'S CALENDAR, the Motion Hearing set for 4/16/2019 at 2:00 PM is VACATED and RESET to 4/15/2019 at 03:00 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell re: 39 Order, Set Motion Hearing, Hearing set as to 39 Order, Set Motion Hearing, 33 Joint MOTION to Certify ClassJoint MOTION (1) Granting Preliminary Approval of the Class Action Settlement; (2) Conditionally Certifying Settlement Class; (3) Appointing Class Representatives and Class Counsel; (4) Approving Notice Plan; and (5) Setting Final Approval Hearing. Signed by Senior Judge David G Campbell on 1/31/2019. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 01/31/2019)

Jan. 31, 2019 PACER
42

ORDER. At the request of counsel, the Court will hold a telephonic conference on 3/27/2019 at 02:00 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell. Counsel for Plaintiffs shall initiate a conference call to include counsel for all parties and the Court. If a dial-in number is to be used, counsel for Plaintiff shall provide the dial-in information to counsel for all parties and the court by 10:00 AM on 3/27/2019. Signed by Senior Judge David G Campbell on 3/27/2019. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 03/27/2019)

March 27, 2019 PACER

~Util - Set/Reset Hearings

March 27, 2019 PACER

Order

March 27, 2019 PACER
43

MINUTE ENTRY for proceedings held before Senior Judge David G Campbell: Telephonic Conference held on 3/27/2019. Discussion is held. The Motion Hearing re: the joint motion for preliminary approval of the class settlement set for 4/16/2019 is continued to 6/18/2019 at 2:00 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell. The deadline for the parties to submit the materials for the hearing is extended to 5/31/2019 at 5:00 p.m. The transcript of this proceeding is ordered sealed for sixty days. APPEARANCES: Andres Holguin-Flores and Thomas Saenz for Plaintiffs. Michael DeSanctis for Defendants. (Court Reporter Patricia Lyons.) Hearing held 2:04 PM to 2:20 PM. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (CLB) (Entered: 03/28/2019)

March 27, 2019 PACER

~Util - Set Deadlines

March 28, 2019 PACER

Telephone Conference

March 28, 2019 PACER

~Util - Set/Reset Motion and R&R Deadlines/Hearings

March 28, 2019 PACER

1 - Common Prompts (Text Only)

March 28, 2019 PACER
44

TRANSCRIPT REQUEST by Kartikay Mehrotra of Bloomberg LP for proceedings held on 01/29/2019, Judge David G Campbell hearing judge(s). (RAP) (Entered: 04/05/2019)

April 5, 2019 PACER
45

ORDER re: 43 . DUE TO A CONFLICT IN THE COURT'S CALENDAR, the motion hearing re class settlement set for 6/18/2019 at 2:00 PM is VACATED and RESET to 6/20/2019 at 02:00 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell. Signed by Senior Judge David G Campbell on 5/16/2019. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 05/16/2019)

May 16, 2019 PACER

~Util - Set/Reset Motion and R&R Deadlines/Hearings

May 16, 2019 PACER

Order

May 16, 2019 PACER
46

NOTICE of Appearance by Oramel Horace Skinner on behalf of Arizona Atorney General, State of. (Skinner, Oramel) (Entered: 05/24/2019)

May 24, 2019 PACER
47

NOTICE of Appearance by Rusty Duane Crandell on behalf of Arizona Atorney General, State of. (Crandell, Rusty) (Entered: 05/24/2019)

May 24, 2019 PACER
48

NOTICE of Appearance by Dana Rae Vogel on behalf of Arizona Atorney General, State of. (Vogel, Dana) (Entered: 05/24/2019)

May 24, 2019 PACER
49

NOTICE of Appearance by Katherine Jessen on behalf of Arizona Atorney General, State of. (Jessen, Katherine) (Entered: 05/24/2019)

May 24, 2019 PACER
50

MOTION to File Amicus Curiae by Arizona Atorney General, State of. (Attachments: # 1 Text of Proposed Order, # 2 Amicus Brief)(Vogel, Dana) (Entered: 05/24/2019)

1 Text of Proposed Order

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2 Amicus Brief

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May 24, 2019 PACER
51

MINUTE ENTRY for proceedings held before Senior Judge David G Campbell: Telephonic Status Conference held on 5/30/2019. Amended Complaint due 6/5/2019. Joint Motion for Preliminary Approval due 6/28/2019. The hearing set for 6/20/2019 is vacated and reset to 7/19/2019 at 02:00 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell. (Court Reporter Patricia Lyons.) Hearing held 10:04 a.m. to 10:15 a.m. (CLB) (Entered: 05/30/2019)

May 30, 2019 PACER

Order on Motion to File Amicus Curiae

May 30, 2019 PACER

Order on Motion for Miscellaneous Relief

May 30, 2019 PACER

Order on Motion to Certify Class

May 30, 2019 PACER
52

ORDER finding as moot 33 Motion to Certify Class; denying 50 Motion to File Amicus Curiae. The parties have advised the court that a new motion for preliminary approval of a class settlement will be filed, and a briefing schedule and hearing date have been set (Doc. 51 ). In light of this development, the pending motion for preliminary approval (Doc. 33 ) is denied as moot, and the motion to file an amicus brief (Doc. 50 ) is denied without prejudice to refiling after the new motion for preliminary approval is filed. Signed by Senior Judge David G Campbell on 5/30/2019. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 05/30/2019)

May 30, 2019 PACER
53

NOTICE of Filing Amended Pleading pursuant to LRCiv 15.1(b) by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated) . (Attachments: # 1 Exhibit Stipulation to File Amended Complaint, # 2 Exhibit Compare_Original Complaint w Amended Complaint)(Holguin-Flores, Andres) (Entered: 06/05/2019)

1 Exhibit Stipulation to File Amended Complaint

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2 Exhibit Compare_Original Complaint w Amended Complaint

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June 5, 2019 PACER
54

AMENDED COMPLAINT against G6 Hospitality LLC, Motel 6 Operating LP filed by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated).(Holguin-Flores, Andres) (Entered: 06/05/2019)

June 5, 2019 RECAP
55

STIPULATION FOR EXTENSION OF TIME TO ANSWER COMPLAINT Stipulation to Extend the Defendants' Deadline to File an Answer to the Amended Complaint by G6 Hospitality LLC, Motel 6 Operating LP. (Refo, Patricia) (Entered: 06/18/2019)

June 18, 2019 PACER
56

ORDER pursuant to 55 Stipulation For Extension of Time To Answer Complaint: Defendants shall file their answer on or before 7/26/2019. The Court will not grant additional extension to this deadline absent truly extraordinary circumstances. Signed by Senior Judge David G Campbell on 6/19/2019. (DGC, nvo) (Entered: 06/19/2019)

June 19, 2019 PACER
57

Joint MOTION for Leave to File Excess Pages by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Attachments: # 1 Text of Proposed Order Granting Joint Motion For Leave to Exceed The Page Limit)(Holguin-Flores, Andres) (Entered: 06/28/2019)

1 Text of Proposed Order Granting Joint Motion For Leave to Exceed The Page Limit

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June 28, 2019 PACER
59

MOTION to Seal Document and Consent Motion to Proceed Under Pseudonyms by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Attachments: # 1 Text of Proposed Order Granting Consent Motion to Proceed Under Pseudonyms)(Holguin-Flores, Andres) (Entered: 06/28/2019)

1 Text of Proposed Order Granting Consent Motion to Proceed Under Pseudonyms

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June 28, 2019 PACER
58

*MOTION for an Order (1) Granting Preliminary Approval of Amended Class Action Settlement, (2) Conditionally Certifying Settlement Class, (3) Appointing Class Representatives and Class Counsel, (4) Approving Notice Plan, and (5) Setting Final Approval Hearing re: 57 Joint MOTION for Leave to File Excess Pages . Filed by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Attachments: # 1 Exhibit 1. Declaration of Mark VanBeest, # 2 Exhibit 2. Washington Consent Decree, # 3 Exhibit 3. Declaration of Andres Holguin-Flores, # 4 Exhibit 4. Declaration of Jane V., # 5 Exhibit 5. Declaration of John E., # 6 Exhibit 6. Declaration of John D., # 7 Exhibit 7. Declaration of John A., # 8 Exhibit 8. Declaration of John W., # 9 Exhibit 9. Declaration of John M., # 10 Exhibit 10. Declaration of Jane F., # 11 Exhibit 11. Declaration of Jane N., # 12 Exhibit 12. Declaration of Angela Ferrante, # 13 Text of Proposed Order Propose Order, # 14 Exhibit A. Agreement, # 15 Exhibit B. Postcard Notice, # 16 Exhibit C. Social Media Notice, # 17 Exhibit D. Class Action Website Notice, # 18 Exhibit E. Claim Form)(Holguin-Flores, Andres) *Modified from lodged to filed pursuant to order 61 ; NEF regenerated on 7/5/2019 (SLQ)/(SCH). (Entered: 06/28/2019)

1 Exhibit 1. Declaration of Mark VanBeest

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2 Exhibit 2. Washington Consent Decree

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3 Exhibit 3. Declaration of Andres Holguin-Flores

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4 Exhibit 4. Declaration of Jane V.

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5 Exhibit 5. Declaration of John E.

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6 Exhibit 6. Declaration of John D.

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7 Exhibit 7. Declaration of John A.

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8 Exhibit 8. Declaration of John W.

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9 Exhibit 9. Declaration of John M.

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10 Exhibit 10. Declaration of Jane F.

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11 Exhibit 11. Declaration of Jane N.

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12 Exhibit 12. Declaration of Angela Ferrante

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13 Text of Proposed Order Propose Order

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14 Exhibit A. Agreement

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15 Exhibit B. Postcard Notice

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16 Exhibit C. Social Media Notice

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17 Exhibit D. Class Action Website Notice

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18 Exhibit E. Claim Form

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July 5, 2019 PACER
61

ORDER - The parties have filed a joint motion for leave to file excess pages. Doc. 57 . IT IS ORDERED that the joint motion (Doc. 57 ) is granted. The Clerk of Court is directed to accept for filing the document lodged on the Court's docket as Doc. 58 . Signed by Senior Judge David G Campbell on 7/5/19. (SLQ) (Entered: 07/05/2019)

July 5, 2019 PACER
60

*Motion to Proceed Under Pseudonyms and Sealed Declarations In Support Thereof by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). (Attachments: # 1 Exhibit Declaration of Jane V., # 2 Exhibit Declaration of Jane V. (True Name), # 3 Exhibit Declaration of John A., # 4 Exhibit Declaration of John A. (True Name), # 5 Exhibit Declaration of John E., # 6 Exhibit Declaration of John E. (True Names), # 7 Exhibit Declaration of Jane F., # 8 Exhibit Declaration of Jane F. (True Name), # 9 Exhibit Declaration of John D., # 10 Exhibit Declaration of John D. (True Name), # 11 Exhibit Declaration of John M., # 12 Exhibit Declaration of John M. (True name), # 13 Exhibit Declaration of Jane N., # 14 Exhibit Declaration of Jane N. (True Name), # 15 Exhibit Declaration of John W., # 16 Exhibit Declaration of John W. (True Name))(Holguin-Flores, Andres) *Modified to change from lodged to filed pursuant to doc. 62 on 7/9/2019 (MAP). (Entered: 06/28/2019)

July 9, 2019 PACER
62

ORDER granting 60 Motion to Proceed Under Pseudonyms. FURTHER ORDERED granting 59 Motion to Seal. The Clerk is directed to file the lodged motion (Doc. 60 ) on the Court's public docket and file Plaintiffs' declarations (Docs. 60-160-16) under seal keeping the same document number. Signed by Senior Judge David G Campbell on 7/9/19. (MAP) (Entered: 07/09/2019)

July 9, 2019 PACER
63

MOTION to File Amicus Curiae by Arizona Atorney General, State of. (Attachments: # 1 Brief, # 2 Exhibit Exhibit A, # 3 Text of Proposed Order)(Jessen, Katherine) (Entered: 07/15/2019)

1 Brief

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2 Exhibit Exhibit A

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3 Text of Proposed Order

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July 15, 2019 PACER

Remark (Public)

July 17, 2019 PACER

Remark: Pro hac vice motion granted for Stacie E Tobin on behalf of defendants. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

July 17, 2019 PACER
64

ORDER: The Unopposed Motion for Leave to File Arizona Attorney General Amicus Curiae Brief (Doc. 63 ) is granted. The Court hereby accepts the proposed Arizona Attorney General Amicus Curiae Brief as a formal submission. The Clerk of the Court distribute a copy of this Order to all counsel of record. Signed by Senior Judge David G Campbell on 7/18/2019. (SST) (Entered: 07/19/2019)

July 19, 2019 PACER
65

TRANSCRIPT REQUEST by Motel 6 Operating LP for proceedings held on 07/19/19, Judge David G Campbell hearing judge(s). (Refo, Patricia) (Entered: 07/19/2019)

July 19, 2019 PACER
66

*MINUTE ENTRY for proceedings held before Senior Judge David G Campbell: Motion Hearing regarding the Motion for an Order granting Preliminary Approval of Amended Class Action Settlement held on 7/19/2019. A Final Approval Hearing is set for February 7, 2020 at 10:00 a.m. in Courtroom 603. See attachment for details. (Court Reporter Patricia Lyons.) Hearing held 1:59 PM to 2:43 PM.(CLB) *Modified on 7/24/2019 to add verbiage re: hearing setting(CLB). (Entered: 07/19/2019)

July 19, 2019 PACER
72

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of MOTION HEARING proceedings held on 07/19/2019, before Judge DAVID G. CAMPBELL. [Court Reporter: Patricia Lyons, RMR, CRR, Telephone number (602) 322-7257]. The ordering party will have electronic access to the transcript immediately. All others may view the transcript at the court public terminal or it may be purchased through the Court Reporter/Transcriber by filing a Transcript Order Form on the docket before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 8/12/2019. Redacted Transcript Deadline set for 8/20/2019. Release of Transcript Restriction set for 10/18/2019. (RAP) (Entered: 08/01/2019)

July 20, 2019 PACER
67

AMENDED DOCUMENT by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). Amendment to 58 MOTION, 66 Motion Hearing Amended Proposed Order and Newly Executed Settlement Agreement. (Attachments: # 1 Exhibit A. Newly Executed Settlement Agreement, # 2 Exhibit B. Postcard Notice, # 3 Exhibit C. Social Media Notice, # 4 Exhibit D. Class Action Website Notice, # 5 Exhibit E. Claim Form)(Holguin-Flores, Andres) (Entered: 07/26/2019)

1 Exhibit A. Newly Executed Settlement Agreement

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2 Exhibit B. Postcard Notice

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3 Exhibit C. Social Media Notice

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4 Exhibit D. Class Action Website Notice

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5 Exhibit E. Claim Form

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July 26, 2019 PACER
68

ORDER setting EMERGENCY HEARING re: 67 Amended Document (NOT Motion/Complaint) filed by Unknown Party. The Court has scheduled an EMERGENCY HEARING (telephonic conference)for 7/30/2019 at 04:30 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell. The dial-in number for the hearing is: 877-402-9753, Access code: 4619653. Signed by Senior Judge David G Campbell on 7/30/2019. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 07/30/2019)

July 30, 2019 PACER

~Util - Set/Reset Deadlines/Hearings

July 30, 2019 PACER

Order

July 30, 2019 PACER
69

MINUTE ENTRY for proceedings held before Senior Judge David G Campbell: Telephonic Conference held on 7/30/2019. Discussion is held regarding Page 21 of the Amended Settlement Agreement submitted to the Court (Doc. 67-1). The parties shall submit a Second Amended Settlement Agreement to the Court by 4:30 p.m. on 7/31/2019. APPEARANCES: Telephonic appearance by Andrew Holguin-Flores and Daniel Ortega for Plaintiffs. Telephonic appearance by Patricia Refo for Defendants. Telephonic appearance by Oramel Skinner, Katherine Jessen, and Dana Vogel for Amicus State of Arizona. (Court Reporter Candy Potter.) Hearing held 4:31 PM to 4:38 PM. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (CLB) (Entered: 07/30/2019)

July 30, 2019 PACER
70

AMENDED DOCUMENT by Unknown Party(named as John M.; individually and on behalf of all others similarly situated), Unknown Party(named as John A.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane F.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane N.; individually and on behalf of all others similarly situated), Unknown Party(named as John E.; individually and on behalf of all others similarly situated), Unknown Party(named as Jane V.; individually and on behalf of all others similarly situated), Unknown Party(named as John W.; individually and on behalf of all others similarly situated), Unknown Party(named as John D.; individually and on behalf of all others similarly situated). Amendment to 69 Telephone Conference, Common Prompts (Text Only) Second Amended Settlement Agreement including Notice Exhibits. (Attachments: # 1 Exhibit A. Fully Executed Second Amended Settlement Agreement, # 2 Exhibit B. Postcard Notice, # 3 Exhibit C. Social Media Notice, # 4 Exhibit D. Class Action Website Notice, # 5 Exhibit E. Claim Form)(Holguin-Flores, Andres) (Entered: 07/31/2019)

1 Exhibit A. Fully Executed Second Amended Settlement Agreement

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2 Exhibit B. Postcard Notice

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3 Exhibit C. Social Media Notice

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4 Exhibit D. Class Action Website Notice

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5 Exhibit E. Claim Form

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July 31, 2019 PACER

1 - Common Prompts (Text Only)

July 31, 2019 PACER

Telephone Conference

July 31, 2019 PACER
71

ORDER. The Court has reviewed the Second Amended Settlement Agreement, and has additional questions. Section XII(C)(1) states that "Each Class Member may be awarded the following amounts, which may be aggregated..." First, the word "may" appears to be ambiguous. Does it mean that the dollar amounts which follow are caps on what the Settlement Administrator may award, and that lower amounts can be awarded in his discretion? If so, have any criteria been provided for his exercise of discretion? If, on the other hand, the intent is to set fixed amounts that will be available to qualifying class members, should the word be "shall"? The language could be changed to read "Each Class Member who qualifies for a distribution under this Agreement shall be awarded the following amounts for which he or she qualifies...," or words to that effect. Second, what is meant by "which may be aggregated"? The parties shall file a joint response, as soon as reasonably possible, that addresses these issues. Signed by Senior Judge David G Campbell on 8-1-19. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC) (Entered: 08/01/2019)

Aug. 1, 2019 PACER

Order

Aug. 1, 2019 PACER
73

RESPONSE re: 71 Order Joint Response to August 1, 2019 Order by Plaintiffs Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party. (Holguin-Flores, Andres) (Entered: 08/01/2019)

Aug. 1, 2019 PACER
74

Additional Attachments to Main Document re: 67 Amended Document (NOT Motion/Complaint) First Addendum to Second Amended Settlement Agreement by Plaintiffs Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party, Unknown Party. (Holguin-Flores, Andres) (Entered: 08/02/2019)

Aug. 2, 2019 PACER
75

ORDER granting 58 Joint motion for preliminary approval of preliminary agreement. Signed by Senior Judge David G Campbell on 8/2/2019.(DGC, nvo) (Entered: 08/02/2019)

Aug. 2, 2019 PACER
76

*MOTION for Leave to File Excess Pages by G6 Hospitality LLC, Motel 6 Operating LP. (Attachments: # 1 Text of Proposed Order)(Refo, Patricia) *Modified to correct event on 1/13/2020 (RMV). (Entered: 01/10/2020)

1 Text of Proposed Order

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Jan. 10, 2020 PACER
77

ORDER granting 76 Motion for Leave to File Excess Pages. The parties may exceed the 17-page limit in filing their joint motion for final approval of the amended class action settlement. The joint motion shall not exceed 28 pages. Signed by Senior Judge David G Campbell on 1/13/2020.(DGC, nvo) (Entered: 01/13/2020)

Jan. 13, 2020 PACER
78

*Joint MOTION Granting Final Approval of Amended Class Action Settlement by G6 Hospitality LLC, Motel 6 Operating LP. (Attachments: # 1 Exhibit Decl of Andres ISO, # 2 Exhibit Decl of Arden ISO, # 3 Exhibit Decl of CDM, # 4 Text of Proposed Order Proposed Order, # 5 Text of Proposed Order Proposed Consent Decree)(Refo, Patricia) *Modified to remove terminated filer on 1/21/2020 (RMV). (Entered: 01/17/2020)

1 Exhibit Decl of Andres ISO

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2 Exhibit Decl of Arden ISO

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3 Exhibit Decl of CDM

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4 Text of Proposed Order Proposed Order

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5 Text of Proposed Order Proposed Consent Decree

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Jan. 17, 2020 RECAP
79

ORDER At the request of counsel, a telephonic conference will be held on 1/30/2020 at 02:30 PM in Courtroom 603, 401 West Washington Street, Phoenix, AZ 85003 before Senior Judge David G Campbell. Counsel for Defendants shall initiate a telephone conference to include counsel for all parties, the attorney general's office, and the Court. If a dial-in number is to be used, counsel for Defendants shall provide the dial-in information to counsel for all parties, the attorney general's office, and the Court no later than 12:00 noon on 1/29/2020. Signed by Senior Judge David G Campbell on 1/27/2020. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (DGC, nvo) (Entered: 01/27/2020)

Jan. 27, 2020 PACER

State / Territory: Arizona

Case Type(s):

Immigration and/or the Border

Key Dates

Filing Date: Jan. 23, 2018

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

People who stayed at a Motel 6 and had their information disclosed to federal immigration authorities between February 1, 2015 and November 2, 2018.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

MALDEF

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Motel 6 Operating, L.P. (Maricopa), Private Entity/Person

G6 Hospitality LLC (Maricopa), Private Entity/Person

Case Details

Causes of Action:

42 U.S.C. § 1983

42 U.S.C. § 1981

42 U.S.C. § 1985

Constitutional Clause(s):

Unreasonable search and seizure

Equal Protection

Availably Documents:

Trial Court Docket

Complaint (any)

Monetary Relief

Injunctive (or Injunctive-like) Relief

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Attorneys fees

Damages

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Amount Defendant Pays: 10,000,000

Order Duration: 2020 - 2023

Content of Injunction:

Discrimination Prohibition

Develop anti-discrimination policy

Implement complaint/dispute resolution process

Reporting

Recordkeeping

Issues

General:

Confidentiality

False arrest

Over/Unlawful Detention

Placement in detention facilities

Records Disclosure

Discrimination-basis:

Immigration status

National origin discrimination

Race discrimination

Type of Facility:

Non-government for profit

Immigration/Border:

Constitutional rights

Deportation - procedure

ICE/DHS/INS raid

National Origin/Ethnicity:

Hispanic