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Plaintiff's Motion to Enforce Settlement Agreement — Adrianna Nicole Ricks v. LexisNexis Risk Solutions, Inc.

Summary

Plaintiff's Motion to Enforce Settlement Agreement in Adrianna Nicole Ricks v. LexisNexis Risk Solutions, Inc., Civil Action No. 4:24-cv-00139, Document 30, filed June 27, 2025, in the U.S. District Court for the Eastern District of Virginia, Newport News Division. Plaintiff Adrianna Ricks, by counsel, moves to enforce the Settlement Agreement among the parties. The motion asks for an Order finding that the Defendant is in breach of the Settlement Agreement, requiring immediate compliance with its terms, and awarding the costs and attorneys' fees associated with seeking enforcement. It refers to an accompanying Memorandum and carries a /s/ signature for Susan M. Rotkis as attorney for the plaintiff, with a certificate of service dated June 27, 2025.

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“Plaintiff's Motion to Enforce Settlement Agreement — Adrianna Nicole Ricks v. LexisNexis Risk Solutions, Inc.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/30-motion-to-enforce-settlement-agreement-by-adrianna-nicole-ri-72199b622a/, SHA-256 6e03401e78420b39b4f4b2919951b25ec64ea61ad43b855f133f56b0a8b5dfa6.

Full text

Case 4:24-cv-00139-EWH-RJK            Document 30      Filed 06/27/25      Page 1 of 2 PageID# 224




                        IN THE UNITED STATES DISTRICT COURT
                        FOR THE EASTERN DISTRICT OF VIRGINIA
                               NEWPORT NEWS DIVISION

   ADRIANNA NICOLE RICKS,

                         Plaintiff,

   v.                                                 Civil Action No. 4:24-cv-00139


   LEXISNEXIS RISK SOLUTIONS, INC.,

                         Defendant.



                                PLAINTIFF’S MOTION TO
                           ENFORCE SETTLEMENT AGREEMENT

         Plaintiff Adrianna Ricks, by counsel, moves to enforce the Settlement Agreement among

  the parties in this case. For the reasons set forth in the accompanying Memorandum, Plaintiff

  respectfully requests an Order finding that the Defendant is in breach of the Settlement Agreement

  in this case, requiring the immediate compliance with the terms of the agreement, and awarding

  the costs and attorneys’ fees associated with seeking enforcement of the Settlement Agreement.

                                               Respectfully submitted,

                                               Adrianna Ricks,

                                                         /s/
                                                 Susan M. Rotkis, VSB 40693
                                                 CONSUMER JUSTICE LAW FIRM PLC
                                                 2290 East Speedway Blvd.
                                                 Tucson, AZ 85719
                                                 T: (602) 807-1504
                                                 F: (480) 613-7733
                                                 E: srotkis@consumejustice.com
                                                 Attorney for Plaintiff
                                                 Adrianna Nicole Ricks




                                                  1
Case 4:24-cv-00139-EWH-RJK           Document 30        Filed 06/27/25     Page 2 of 2 PageID# 225




                                  CERTIFICATE OF SERVICE

         I hereby certify that on June 27, 2025, 1 electronically filed the foregoing with the Clerk

  of the Court using the ECF system, which will send notice of such filing to all attorneys of record

  in this matter. Since none of the attorneys of record are non-ECF participants, hard copies of the

  foregoing have not been provided via personal delivery or by postal mail.

                                                         /s/
                                                 Susan M. Rotkis, VSB 40693
                                                 CONSUMER JUSTICE LAW FIRM PLC
                                                 2290 East Speedway Blvd.
                                                 Tucson, AZ 85719
                                                 T: (602) 807-1504
                                                 F: (480) 613-7733
                                                 E: srotkis@consumejustice.com
                                                 Attorney for Plaintiff
                                                 Adrianna Nicole Ricks




                                                  2

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