In Re: Ford Derivative Litigation

[Additional captions on following pages]
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
PAUL GAGNE, Derivatively On Behalf Of
FORD MOTOR COMPANY,
Plaintiff,
v.
JAMES D. FARLEY, JR., et al.,
Defendants,
and
FORD MOTOR COMPANY, A Delaware
Corporation,
Nominal Defendant.
Case No.: 24-cv-12486
Honorable Linda V. Parker
RICHARD RICH, Derivatively On Behalf
Of FORD MOTOR COMPANY,
Plaintiff,
v.
JAMES D. FARLEY, JR., et al.,
Defendants,
and
FORD MOTOR COMPANY, A Delaware
Corporation,
Nominal Defendant.
(Consolidated from:
Case No. 2:24-cv-12906)
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SURESH RAM, Derivatively On Behalf Of
FORD MOTOR COMPANY,
Plaintiff,
v.
JAMES D. FARLEY, JR., et al.,
Defendants,
and
FORD MOTOR COMPANY, A Delaware
Corporation,
Nominal Defendant.
(Consolidated from:
Case No. 24-cv-13160)
HAL YUROW, Derivatively On Behalf Of
FORD MOTOR COMPANY,
Plaintiff,
v.
JAMES D. FARLEY, JR., et al.,
Defendants,
and
FORD MOTOR COMPANY, A Delaware
Corporation,
Nominal Defendant.
(Consolidated from:
Case No. 24-cv-13222)
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BEREL ROSENFELD IRA and LEAH
ROSENFELD IRA, Derivatively On
Behalf Of FORD MOTOR COMPANY,
Plaintiffs,
v.
JAMES D. FARLEY, JR., et al.,
Defendants,
and
FORD MOTOR COMPANY, A Delaware
Corporation,
Nominal Defendant.
(Consolidated from:
Case No. 25-cv-10119)
ORDER GRANTING
PLAINTIFFS BEREL ROSENFELD IRA AND LEAH ROSENFELD IRA’S
MOTION FOR APPOINTMENTOF CO-LEAD COUNSEL
This matter comes before the Court on the unopposed motion of Plaintiffs
Berel Rosenfeld IRA and Leah Rosenfeld IRA to appoint Miller Law and Weiss
Law as Co-Lead Counsel. 1 Having considered the motion, as well as the
1 Plaintiffs Berel Rosenfeld IRA and Leah Rosenfeld IRA also moved for
consolidation of these matters. However, the Court already has entered a
consolidation order. The motion would have been unnecessary had counsel, when
filing their Complaint, identified the action as a companion matter to the earlier-
filed, related derivative actions. This was mandatory under Eastern District of
Michigan Local Rule 83.11(b)(7)(C). At that point, the Judges assigned the
matters would have conferred, likely transferred the later-filed action to the
undersigned pursuant to Eastern District of Michigan Local Rule 83.11(b)(7)(D),
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accompanying exhibits, the Court GRANTS the motion and ORDERS, as
follows:
1. 	The consolidated cases are renamed and future filings shall use this
caption:
In re Ford Derivative Litigation 	Case No.: 24-cv-12486
Honorable Linda V. Parker
2. 	Having given due consideration to the relevant factors set forth in
Federal Rule of Civil Procedure 23(g)(1) and (4), including, without limitation,
Rule 23(g)(1)(A)(i)-(iv), and finding that the Proposed Co-Lead Counsel meet the
adequacy requirements thereunder, The Miller Law Firm, P.C. and Weiss Law are
appointed as Co-Lead Counsel in accordance with Rule 23(g)(3).
3. 	Co-Lead Counsel will be responsible for and have plenary authority to
prosecute any and all claims of Plaintiffs, derivatively on behalf of Ford Motor
Co., and to provide general supervision of the activities of Plaintiffs’ counsel in the
Action. Specifically, Co-Lead Counsel shall have the following responsibilities,
duties, and sole authority to:
a. 	Draft and file a consolidated complaint and have final authority regarding
what claims and parties are to be included;
and the undersigned, after notice to the parties, would have sua sponte ordered
consolidation under Local Rule 83.11(b)(2).
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b. Determine and present in pleadings, briefs, motions, oral argument, or
such other fashion as may be appropriate, to the Court and opposing
parties, the position of Plaintiffs on matters arising during the pretrial
proceedings;
c. 	Coordinate and conduct discovery on behalf of Plaintiffs consistent with
the requirements of the Federal Rules of Civil Procedure, the Local Rules
of the United States District Court for the Eastern District of Michigan,
and the undersigned’s Practice Guidelines;
d. Consult with and employ consultants and/or expert witnesses;
e. 	Conduct all pre-trial proceedings on behalf of Plaintiffs;
f. 	Enter any stipulations and agreements with Defendants;
g. Sign all papers filed on behalf of Plaintiffs;
h. Convene meetings of any or all Plaintiffs’ counsel, as necessary;
i. 	Form task-specific subcommittees of Plaintiffs’ counsel, as appropriate;
j. 	Conduct settlement negotiations with Defendants;
k. Maintain an up-to-date service list of all Plaintiffs’ counsel for any and
all consolidated cases in this Action, and promptly advise the Court and
Defendants’ counsel of any changes thereto;
l. 	Receive and distribute to Plaintiffs’ counsel, as appropriate, discovery,
pleadings, correspondence, and other documents from Defendants’
counsel or the Court that are not electronically filed;
m. Appear at court-noticed status conferences and hearings;
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n. Be the contact person for, and maintain authority on behalf of, all
Plaintiffs’ counsel and as the attorneys of record with whom the Court
will be dealing throughout the course of the litigation;
o. Delegate specific tasks to other Plaintiffs’ counsel in a manner to avoid
duplicative efforts and ensure that the litigation on behalf of Plaintiffs is
conducted effectively, efficiently, and economically;
p. Otherwise coordinate the work of all Plaintiffs’ counsel, and perform
such other duties as the Co-Lead Counsel deem necessary to advance the
litigation or as authorized by further Order of the Court;
q. Maintain and collect time and expense records for work performed on a
regular basis, including all time billed, costs incurred, and other
disbursements made by Plaintiffs’ counsel whose work Co-Lead Counsel
has specifically authorized, and submit at the Court’s request, in writing,
ex parte and in camera reports to the Court regarding time billed in the
prosecution of this Action. At such time as may be appropriate, Co-Lead
Counsel will also recommend allocation of fees and expenses subject to
the Court’s approval;
r. 	Fund the necessary and appropriate costs of discovery and other common
benefit efforts; and
s. 	Perform such other functions as necessary to effectuate the above
responsibilities or as may be expressly authorized by further Order of the
Court.
It is the Court’s intent that, as to all matters common to these coordinated
cases, and to the fullest extent consistent with the independent fiduciary
obligations owed by any and all Plaintiffs’ counsel to their clients and any putative
class, pretrial proceedings shall be conducted by and through Co-Lead Counsel.
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4. 	This Order shall apply to any action subsequently consolidated with
this Action.
SO ORDERED.
s/ Linda V. Parker
LINDA V. PARKER
U.S. DISTRICT JUDGE
Dated: November 4, 2025
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