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Patrick N. Keegan, Esq. (SBN 167698) KEEGAN & BAKER, LLP 6870 Embarcadero Lane Carlsbad, California 92011 Tel: (760) 929-9303 Fax: (760) 929-9260 Steven A. Wickman, Esq. (SBN 165149) Christina E. Wickman, Esq. (SBN 236882) WICKMAN & WICKMAN 3170 4TH Avenue, Suite 200 San Diego, California 92103-5850 Tel: (619) 482-1207 Fax: (619) 271-8656 James P. Frantz, Esq. (SBN 87492) FRANTZ LAW GROUP, APLC 402 West Broadway, Suite 860 San Diego, CA 92101 Tel: (619) 233-5945 Fax: (619) 525-7672 Attorneys for Plaintiff DANIEL PEPPER SUPERIOR COURT OF THE STATE OF CALIFORNIA

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Notice of Motion for Approval of Attorneys Fees

DANIEL PEPPER, on behalf of himself and others Case No. 37-2011-00088752-CU-BT-CTL similarly situated, Assigned to Hon. Joel R. Wohlfeil, Dept. C-73 Plaintiff, PLAINTIFFS NOTICE OF MOTION AND vs. MOTION FOR APPROVAL OF AN AWARD OF ATTORNEYS FEES AND COSTS TO MIDLAND CREDIT MANAGEMENT, INC.; CLASS COUNSEL; AND AN INCENTIVE ENCORE CAPITAL GROUP, INC.; DOES 1 AWARD TO THE CLASS REPRESENTATIVE through 20, inclusive, PLAINTIFF Date: August 23, 2013 Time: 10:30 a.m. _________________________________________ Place: Department C-73 TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS: PLEASE TAKE NOTICE that on August 23, 2013 at 10:30 a.m., or as soon thereafter as counsel can be heard in Department C-73 of the San Diego Superior Court, located at 330 West Broadway, San Diego, California 92011, the appointed Class Representative, Plaintiff Daniel Pepper, (Class Representative or Plaintiff), by and through his attorneys, will, and hereby does, move this Court for an Defendants.

Case No. 37-2011-00088752-CU-BT-CTL

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Order and entry of Judgment finally approving the class action settlement with Defendant Midland Credit Management, Inc. and Defendant Encore Capital Group, Inc. (hereinafter collectively referred to as Defendants); and for (1) an award of attorneys fees and reimbursement of costs to Class Counsel in the total amount of $2,450,000; (2) class notice and claims administration fees and costs to Gilardi & Co. LLC in the total amount of $1,000,000; and (3) incentive or service award of $50,000 to the Class Representative for his significant efforts made on behalf of the Class. This motion is made, pursuant to Code of Civil Procedure 382, California Rules of Court 3.769(b) and (g), and the Courts inherent power to supervise class action litigation and the settlement of class action cases, on the grounds that pursuant to the terms of the settlement the Class Representative reached with Defendants, the payment of attorneys fees and costs to Class Counsel and an incentive award to the Class Representative in the amounts requested is fair, reasonable and justified. This motion is based on this notice of motion and motion, the Settlement Agreement (previously filed with the Court on February 8, 2013, attached as Exhibit 1 to the Supplemental Reply Declaration of Patrick . Keegan in support of Plaintiffs Motion for Preliminary Approval of Class Action Settlement), the Order Preliminarily Approving Settlement and Providing for Notice of the Settlement entered by the Court on February 13, 2013, the accompanying memorandum of points and authorities, the accompanying declarations of Patrick N. Keegan, Steven Wickman, James P. Frantz, Todd M. Friedman, Brian R. Strange, Tricia Solorzano, Alan Vasquez, and Daniel Pepper, and such other documentary and testimonial evidence as shall be submitted to this Court and may be presented at the hearing on this motion, if any. Dated: July 15, 2013 KEEGAN & BAKER, LLP /s/ Patrick N. Keegan Patrick N. Keegan, Esq. Attorney for Plaintiff Daniel Pepper

Notice of Motion for Approval of Attorneys Fees

Case No. 37-2011-00088752-CU-BT-CTL