Peter Schuman et al v. Microchip Technology Incorporated et al

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28 STIPULATION AND ORDER RE: PAYMENT OF SETTLEMENT PROCEEDS
TO HEIRS OF DECEASED CLASS MEMBERS 	Case No. 4:16-cv-05544-HSG
1
Michael Rubin (SBN 80618)
Matthew J. Murray (SBN 271461)
Marisa C. Lowe (SBN 366248)
ALTSHULER BERZON LLP
177 Post Street, Suite 300
San Francisco, CA 94108
Telephone: 	(415) 421-7151
Facsimile: 	(415) 362-8064
Email: 	mrubin@altber.com
mmurray@altber.com
mlowe@altber.com
Cliff Palefsky (SBN 77683)
Keith Ehrman (SBN 106985)
MCGUINN, HILLSMAN & PALEFSKY
220 Jackson Street, Suite 350
San Francisco, CA 94111
Telephone: 	(415) 421-9292
Facsimile: 	(415) 403-0202
Email: 	cp@mhpsf.com
keith@mhpsf.com
William B. Reilly (SBN 177550)
LAW OFFICE OF WILLIAM REILLY
86 Molino Avenue
Mill Valley, CA 94941
Telephone: 	(415) 225-6215
Facsimile: 	(415) 634-2897
Email: 	bill@williambreilly.com
Attorneys for Plaintiffs and the Certified Class
[Attorneys for Defendants on the next page]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
PETER SCHUMAN, an individual, and
WILLIAM COPLIN, an individual, on behalf
of themselves and on behalf of others similarly
situated,
Plaintiffs,
v.
MICROCHIP TECHNOLOGY
INCORPORATED, a corporation; ATMEL
CORPORATION, a corporation; and ATMEL
CORPORATION U.S. SEVERANCE
GUARANTEE BENEFIT PROGRAM, an
employee benefit plan,
Defendants.
Case No. 4:16-CV-05544-HSG
CLASS ACTION
STIPULATION AND ORDER RE: PAYMENT
OF SETTLEMENT PROCEEDS TO HEIRS OF
DECEASED CLASS MEMBERS
Hearing Date: 	October 15, 2026
Time: 	2:00 p.m.
Courtroom: 	2, Floor 4
Judge: 	Hon. Haywood S. Gilliam, Jr.
Action Filed: 	September 29, 2016
Case 4:16-cv-05544-HSG Document 262 Filed 10/09/26 Page 1 of 6

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28 STIPULATION AND ORDER RE: PAYMENT OF SETTLEMENT PROCEEDS
TO HEIRS OF DECEASED CLASS MEMBERS 	Case No. 4:16-cv-05544-HSG
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OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.,
Mark G. Kisicki (CA SBN 150057)
mark.kisicki@ogletreedeakins.com
Elizabeth M. Soveranez (AZ SBN 024009) admitted pro hac vice
elizabeth.soveranez@ogletreedeakins.com
2415 E. Camelback Road, Suite 800
Phoenix, AZ 85016
Telephone: 602.778.3700
Fax: 602.778.3750
Mark Schmidtke (IN SBN 1733-45) admitted pro hac vice
mark.schmidtke@ ogletreedeakins.com
56 S. Washington Street, Suite 302
Valparaiso, IN 46383
Telephone: 219.242.8668
Fax: 219.242.8669
Erika L. Leonard erika.leondard@ogletree.com
301 Congress Avenue, Suite 1150
Austin, TX 78701
Telephone: (512) 344-4700
Facsimile: (512) 344-4701
Attorneys for Defendants
Case 4:16-cv-05544-HSG Document 262 Filed 10/09/26 Page 2 of 6

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28 STIPULATION AND ORDER RE: PAYMENT OF SETTLEMENT PROCEEDS
TO HEIRS OF DECEASED CLASS MEMBERS 	Case No. 4:16-cv-05544-HSG
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STIPULATION RE: PAYMENT TO HEIRS OF DECEASED CLASS MEMBERS
WHEREAS, the parties reached a settlement of this action in June 2026 and executed a
Memorandum of Understanding (“MOU”) on June 30, 2026 containing the essential terms of the
settlement;
WHEREAS, on August 3, 2026, the Court granted Plaintiffs’ Motion for Preliminary Approval;
WHEREAS, under the terms of the MOU, Defendant Microchip is to issue two settlement
checks to each class member, with the first check representing unpaid severance benefits and the second
check representing interest on the unpaid severance calculated from the date of the class member’s
termination of employment through the Effective Date of the settlement;
WHEREAS, under the terms of the MOU, the first check for unpaid severance is to be treated as
wage income with payroll taxes withheld, while the second check for interest is not to be treated as wage
income and will not have payroll taxes withheld;
WHEREAS, under the terms of the MOU and as explained in the Court-approved Notice sent to
class members, in order to receive the two settlement checks a class member must complete and submit
to Microchip an IRS Form W-4 and an IRS Form W-9;
WHEREAS, under the terms of the MOU, the IRS Form W-4 is to be used in connection with
the payment representing severance benefits, because the parties contemplated that this payment would
be treated as wage income, with payroll taxes withheld;
WHEREAS, plaintiffs’ counsel recently learned that class member Nora Davanzo-Ward died in April
2018; class member Debra Wiley died in August 2018; and class member David Sabo died in July 2025;
WHEREAS, under the terms of the MOU and as agreed upon by the parties in July 2026, Ms.
Davanzo-Ward was entitled to a settlement payment totaling more than $16,600; Ms. Wiley was entitled to a
settlement payment totaling more than $17,400; and Mr. Sabo was entitled to a settlement payment totaling
more than $79,800 (the exact totals will be determined after interest is calculated through the Effective Date,
following final approval of the settlement);
WHEREAS, as to class member Ms. Davanzo-Ward, for the reasons set forth in the accompanying
Case 4:16-cv-05544-HSG Document 262 Filed 10/09/26 Page 3 of 6

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28 STIPULATION AND ORDER RE: PAYMENT OF SETTLEMENT PROCEEDS
TO HEIRS OF DECEASED CLASS MEMBERS 	Case No. 4:16-cv-05544-HSG
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Declaration of Keith Ehrman, the parties are satisfied that the sole legal heir of her estate is her husband
Robert Benjamin Ward, and that Robert Benjaim Ward is entitled to receive 100% of the settlement payment
owed to Ms. Davanzo-Ward in this action;
WHEREAS, as to class member Debra Wiley, for the reasons set forth in the accompanying
Declaration of Keith Ehrman, the parties are satisfied that the sole legal heir of her estate is her only child,
Renessa Wiley White, and that Renessa Wiley White is entitled to receive 100% of the settlement payment
owed to Debra Wiley in this action;
WHEREAS, Plaintiffs’ counsel and Defendant’s counsel have conferred and agree that asking the
heirs of deceased class members to submit a Form W-4 and have payroll taxes withheld (as if the heir had
been an employee of Microchip) is neither necessary nor appropriate;
WHEREAS, Plaintiffs’ counsel and Defendants’ counsel agree that the most appropriate way for the
heirs of Ms. Davanzo-Ward and Ms. Riley to receive the class member’s settlement payment is to have the
heir complete only an IRS Form W-9 in his or her own name and submit the Form W-9 to Microchip, without
the need to submit an IRS Form W-4, and for Microchip to then issue a single check payable to the heir for
the full amount of the class members’ settlement sum (unpaid severance benefits plus interest), with no
payroll taxes withheld;
THEREFORE, the parties ask the Court for permission to deviate from the payment process
prescribed by the terms of the MOU with respect to the heirs of deceased class members Debra Wiley
and Nora Davanzo-Ward, such that the heirs do not need to submit a Form W-4 and instead may submit
to Microchip only a Form W-9 in the name of the heir, and Microchip may thereafter issue a single
settlement check payable directly to the heir, representing payment of both the unpaid severance benefits
and interest thereon, with no payroll withholding.
IT IS SO STIPULATED.
Case 4:16-cv-05544-HSG Document 262 Filed 10/09/26 Page 4 of 6

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28 STIPULATION AND ORDER RE: PAYMENT OF SETTLEMENT PROCEEDS
TO HEIRS OF DECEASED CLASS MEMBERS 	Case No. 4:16-cv-05544-HSG
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Dated: October 8, 2026 	__/s/ Keith Ehrman___________________
Keith Ehrman
Attorney for Plaintiffs and Class Members
Dated: October 8, 2026 	__/s/ Elizabeth Soveranez______________
Elizabeth Soveranez
Attorney for Defendants
SIGNATURE ATTESTATION PURSUANT TO
CIVIL LOCAL RULE Civil L.R. 5-1(h)(3)
I, Keith Ehrman, am the ECF User whose ID and password are being used to file this
document. In compliance with N.D. Cal. Civil L.R. 5-1(h)(3), I hereby attest that concurrence in the
filing of the document has been obtained from Elizabeth Soveranez, attorney for Defendants, as
indicated by a “conformed” signature (/s/) within this e-filed document.
/s/ Keith Ehrman
Keith Ehrman
Attorney for Plaintiff
ORDER
THE COURT HAVING CONSIDERED THE STIPULATION AND EVIDENCE SUBMITTED
BY THE PARTIES, AND GOOD CAUSE APPEARING,
IT IS HEREBY ORDERED AS FOLLOWS:
1. 	With respect to class member Nora Davanzo-Ward, her sole legal heir Robert Benjamin
Ward may submit an IRS Form W-9 to Microchip in his own name, and Microchip shall
thereafter issue a check payable to Robert Benjamin Ward for the full settlement amount to
which Nora Davanzo-Ward is entitled under the settlement (unpaid severance benefits plus
interest) with no payroll taxes withheld. Robert Benjamin Ward shall not be required to
submit a Form W-4 to Microchip.
2. 	With respect to deceased class member Debra Wiley, her sole legal heir Renessa Wiley
White may submit an IRS Form W-9 to Microchip in her own name, and Microchip shall
Case 4:16-cv-05544-HSG Document 262 Filed 10/09/26 Page 5 of 6

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28 STIPULATION AND ORDER RE: PAYMENT OF SETTLEMENT PROCEEDS
TO HEIRS OF DECEASED CLASS MEMBERS 	Case No. 4:16-cv-05544-HSG
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thereafter issue a check payable to Renessa Wiley White for the full settlement amount to
which Debra Wiley is entitled under the settlement (unpaid severance benefits plus interest)
with no payroll taxes withheld. Renessa Wiley White shall not be required to submit a Form
W-4 to Microchip.
Dated: 10/9/2026 ____________________________
HON. HAYWOOD S. GILLIAM, JR.
United States District Judge
Case 4:16-cv-05544-HSG Document 262 Filed 10/09/26 Page 6 of 6