Case 1:15-cv-08372-JPO Document 30 Filed 03/11/16 Page 1 of 6

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
STEPHANIE FUENTES, JETAIME HOWARD,
MIANIKA SMITH, SHARI GOODMAN, and
JERMAIN HAYES, Individually And On Behalf of
All Others Similarly Situated,,
Plaintiffs,
- against -

Civil Action No. 15-cv-8372

ECF CASE

UNIRUSH, LLC d/b/a UNIRUSH FINANCIAL

SERVICES, RUSH COMMUNICATIONS, LLC,
RUSH COMMUNICATIONS of NYC, INC.,
META FINANCIAL GROUP, INC., and
METABANK,
Defendants.

STIPULATED MOTION TO STAY AND PROPOSED ORDER

Plaintiffs Stephanie Fuentes, Jetaime Howard, Mianika Smith, Shari Goodman, and
Jermain Hayes and Defendants UniRush, LLC d/b/a UniRush Financial Services, Rush
Communications, LLC, Rush Communications of NYC, Inc., Meta Financial Group, Inc., and
Metabank (jointly, the Parties), through their respective counsel, respectfully submit this
Stipulated Motion to Stay. In support of this Motion to Stay, the Parties state:
WHEREAS, previously the Parties informed the Court that they had been involved in
discussions to seek a global resolution across four cases (the Actions):
x

Fuentes v. UniRush, LLC et al., Case No. 1:15-cv-08372 (S.D.N.Y.)

Huff v. UniRush, LLC et al., Case No. 2:15-cv-02253-KJM-CMK (E.D.Cal.)

Jones v. UniRush, LLC et al., Case No. 5:15-cv-05996-JLS (E.D. Pa.)

Peterkin v. UniRush, LLC et al., Case No. 1:15-cv-08573 (S.D.N.Y.)

Case 1:15-cv-08372-JPO Document 30 Filed 03/11/16 Page 2 of 6

WHEREAS, all of the four above-mentioned cases contain overlapping claims and arose
from a substantially similar series of events and seek to represent an overlapping nationwide
class;
WHEREAS, Plaintiffs and Defendants in this Action are finalizing the terms of a
Settlement Agreement, and the Parties in all Actions will be seeking approval of the agreement
in this Action, which was filed first;
WHEREAS, approval of the settlement will resolve the claims in this case;
WHEREAS, the Parties believe they will file their motion for preliminary approval
within 60 days of this Motion;
WHEREAS, the Parties believe that it is in their interests to pursue approval of the
Settlement rather than proceed with litigation of these claims;
NOW, THEREFORE, it is stipulated by and between the Parties, by and through their
respective counsel, that:
1.

This case shall be stayed pending the Parties seeking full approval of the

Settlement in this Action, and during the period the Court considers this request, all deadlines,
conferences, and hearing dates are adjourned, and
2.

The Parties will jointly report to the Court should the Parties not file their motion

for preliminary approval within 60 days of this Motion.

Case 1:15-cv-08372-JPO Document 30 Filed 03/11/16 Page 3 of 6

Case 1:15-cv-08372-JPO Document 30 Filed 03/11/16 Page 4 of 6

Case 1:15-cv-08372-JPO Document 30 Filed 03/11/16 Page 5 of 6

Case 1:15-cv-08372-JPO Document 30 Filed 03/11/16 Page 6 of 6

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
STEPHANIE FUENTES, JETAIME HOWARD,
MIANIKA SMITH, SHARI GOODMAN, and
JERMAIN HAYES, Individually And On Behalf of
All Others Similarly Situated,,
Plaintiffs,

Civil Action No. 15-cv-8372

- against -

ECF CASE

UNIRUSH, LLC d/b/a UNIRUSH FINANCIAL

SERVICES, RUSH COMMUNICATIONS, LLC,
RUSH COMMUNICATIONS of NYC, INC.,
META FINANCIAL GROUP, INC., and
METABANK,
Defendants.

[PROPOSED] ORDER
This Court, having duly considered the Parties Stipulated Motion To Stay, and good
cause appearing, hereby orders as follows:
1.

This case shall be stayed pending the Parties seeking full approval of the

Settlement in this Action, and during the period the Court considers this request, all deadlines,
conferences, and hearing dates are adjourned, and
2.

The Parties will jointly report to the Court should the Parties not file their motion

for preliminary approval within 60 days of this Motion.

IT IS SO ORDERED
Dated: _________________
Hon. J. Paul Oetken
United States District Judge