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Case 1:96-cv-01285-TFH Document 3697 Filed 02/24/11 Page 1 of 36 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ELOUISE PEPION COBELL, et al., ) ) Plaintiffs, ) ) v. ) Case No. 1:96cv01285(TFH) ) KEN SALAZAR, Secretary of the Interior, ) et al., ) ) Defendants. ) __________________________________________) DEFENDANTS OBJECTIONS TO CLASS REPRESENTATIVES PETITION FOR INCENTIVE AWARDS AND EXPENSES INTRODUCTION In addition to class counsels request for $223 million in attorney fees and $1.2 million in expenses from class members settlement funds, the class representatives seek personal awards totaling $13,056,274.50. The four class representatives, Elouise Cobell, James Louis LaRose, Thomas Maulson, and Penny Cleghorn, have garnered praise for their efforts on trust reform for Individual Indian Money (IIM) Accounts. But the millions of dollars that they ask to be paid in incentives and expenses (which they did not personally incur) is grossly excessive and threatens their fiduciary obligation to the classes. Together they seek $2.5 million as an incentive award, as a bonus for their efforts, which by itself is many times higher than the most generous awards bestowed in any reported case in this Circuit. Incentive awards are supposed to be modest remuneration that do not markedly diminish the moneys available to class members. Their $2.5 million incentive request is neither modest nor fair to the classes. Rather, the four...
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