BROWN v. AMERICAN HOME PROD

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 4, 2024
Docket2:99-cv-20593
StatusUnknown

This text of BROWN v. AMERICAN HOME PROD (BROWN v. AMERICAN HOME PROD) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BROWN v. AMERICAN HOME PROD, (E.D. Pa. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

IN RE: DIET DRUGS : (PHENTERMINE/FENFLURAMINE/ : MDL NO. 1203 DEXFENFLURAMINE) PRODUCTS : LIABILITY LITIGATION : THIS DOCUMENT RELATES TO: : : SHELIA BROWN, et al. : CIVIL ACTION : v. : : NO. 99-20593 AMERICAN HOME PRODUCTS : CORPORATION :

MEMORANDUM IN SUPPORT OF PRETRIAL ORDER NO. 9576 Bartle, J. March 4, 2024 This is a further proceeding in this massive class action settlement arising out of claims against Wyeth related to the marketing of its Diet Drugs Pondimin and Redux which plaintiffs alleged to have caused their valvular heart disease. Before the court is the joint petition of class counsel Michael D. Fishbein, Esq. and the law firm of Levin, Sedran & Berman, LLP for an award of counsel fees relating to work performed from March 25, 2022 through December 31, 2023 in conceiving, designing, negotiating, drafting and obtaining judicial approval of the Eleventh Amendment to the Class Action Settlement Agreement (“Eleventh Amendment”) as well as for responding to requests to the Claim Administrator and assisting unrepresented claimants as set forth in Section II.S.3. of the Eleventh Amendment. They seek a total of $408,137.50 - $138,337.50 for Michael D. Fishbein, Esq., and $269,800 for Levin, Sedran & Berman, LLP. This court has previously awarded

fees in Pretrial Order (“PTO”) Nos. 2262, 2859, 7763A, 8516, 8646, 8869, 9102, 9294, 9465, 9460, 9502, and 9514. I On August 28, 2023, the court approved the Eleventh Amendment without objection. See PTO No. 9558. The parties devised this amendment to further streamline claims processing for the approximately 3,000 class members that remain eligible to make a Matrix claim if they develop a qualifying medical condition within the next four decades. Pursuant to Section II.P. of the Eleventh Amendment, Wyeth agreed to pay class counsel’s fees. It retained its right to object to such proposed fees and stipulated that such fees

shall not exceed the lodestar calculation. Wyeth has not filed any objections. A lodestar calculation is one way of calculating a reasonable rate for counsel and is determined by multiplying the number of hours counsel reasonably expended on the matter by counsel’s reasonable hourly rate. Class counsel now petitions the court for fees based on 498 hours they expended in drafting and negotiating the Eleventh Amendment as well as work communicating with pro se claimants in connection with this amendment. The parties entered into the initial Class Action Settlement Agreement (“Agreement”) on November 18, 1999. Due to difficulties experienced in reviewing, identifying, and timely

paying claims to eligible claimants, the parties created and executed multiple amendments to streamline the review process of medical claims. Between 2006 and 2019, class counsel submitted annual petitions for reimbursement of fees and expenses, which were reviewed by the court. During that time, approximately forty-two thousand claims were processed pursuant to the Agreement. As time passed, the number of claims has greatly decreased. From 2019 through 2022, the American Home Products Settlement Trust (“Trust”), which was responsible for paying claims, received sixteen Matrix claims and paid out $7,743,309 in Matrix benefits. In 2022, the Trust paid out $1,478,993 in

claims, yet incurred $983,672 in expenses. In the first quarter of 2023, the Trust did not pay out any claims, but incurred $60,000 in trustee fees and $82,807 in expenses. The claims review system was also slow – taking around eleven months to pay a single claim. As the pace of claims slows, the high administrative costs of the Trust and its claims processing system have become disproportionately large. Concerned that such a system could be a waste of settlement funds, the parties executed the Eleventh Amendment in the interest of decreasing claims processing times as well as greatly decreasing the costs of administration. II

The instant petition, as noted above, has received no objections from Wyeth. Nonetheless, the court must conduct a “thorough judicial review” of the requested fee award as required in all class action settlements. In re Gen. Motors Corp. Pick-Up Truck Fuel Tank Prods. Liab. Litig., 55 F.3d 768, 819 (3d Cir. 1995). The court will analyze the reasonableness of the settlement in light of the factors outlined in Gunter v. Ridgewood Energy Corp., 223 F.3d 190 (3d Cir. 2000). It will then apply a lodestar cross-check. In determining the reasonableness of a proposed award for counsel in class action settlements such as this, our Court of Appeals requires a district court to consider the following ten factors:

(1) the size of the fund created and the number of beneficiaries, (2) the presence or absence of substantial objections by members of the class to the settlement terms and/or fees requested by counsel, (3) the skill and efficiency of the attorneys involved, (4) the complexity and duration of the litigation, (5) the risk of nonpayment, (6) the amount of time devoted to the case by plaintiffs' counsel, (7) the awards in similar cases, (8) the value of benefits attributable to the efforts of class counsel relative to the efforts of other groups, such as government agencies conducting investigations, (9) the percentage fee that would have been negotiated had the case been subject to a private contingent fee arrangement at the time counsel was retained, and (10) any innovative terms of settlement. In re Diet Drugs Prods. Liab. Litig., MDL No. 1203, 2013 WL 3326480, at *3 (E.D. Pa. June 28, 2013) (citing Gunter, 223 F.3d at 195).1 These factors shall not be applied in a formulaic way, and a district court must recognize that one factor may outweigh others. Id. What is important is that the court “evaluate what class counsel actually did and how it benefitted the class.” In re AT&T Corp. Sec. Litig., 455 F.3d 160, 165-66 (3d Cir. 2006) (citing In re Prudential Ins. Co. Am. Sales Prac. Litig. Agent Actions, 148 F.3d 283, 342 (3d Cir. 1998)). A. Size of Fund The size of the Settlement Fund totaled approximately $6.44 billion. The Eleventh Amendment operates to benefit the 3,000 remaining class members that remain eligible for benefits under the Agreement. It does so by speeding up claims

processing timelines and preserving limited funds. While this is only a fraction of those individuals originally eligible for a distribution, the work counsel has done has benefitted all

1. These factors were articulated in the context of class action settlements where the court considered the reasonableness of a percentage-of-recovery fee award. Although the award proposed here is calculated based on the lodestar method of recovery, the court will still consider these factors in order to assure that the award is reasonable. The choice of methodology “rest[s] within the district court’s sound discretion.” In re Gen. Motors Corp, 55 F.3d at 821. claimants remaining eligible for additional payments. Thus this factor weighs in favor of granting the proposed fee award. B. Presence or Absence of Substantial Objections There have been no objections to the petition for

counsel fees. Further, there have been no objections to counsel fee petitions since 2007. All prior objections were overruled, some rulings were appealed, and our Court of Appeals affirmed. See, e.g., In re Diet Drugs Prods. Liab.

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BROWN v. AMERICAN HOME PROD, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-american-home-prod-paed-2024.