February 20, 2026 at 5:55 AM
📢 Early recovery tests at Eclipse Metals’ Greenland project show its rare earths are strongly suited to magnetic separation, which could enable efficient beneficiation.
👉 Bot to check Bluesky account creation dates
👉 Bot to check Bluesky account creation dates
Greenland rare earths play shows strong magnetic pull for Eclipse
www.theage.com.au
February 20, 2026 at 5:54 AM
📢 Early recovery tests at Eclipse Metals’ Greenland project show its rare earths are strongly suited to magnetic separation, which could enable efficient beneficiation.
👉 Bot to check Bluesky account creation dates
👉 Bot to check Bluesky account creation dates
📢 Early recovery tests at Eclipse Metals’ Greenland project show its rare earths are strongly suited to magnetic separation, which could enable efficient beneficiation.
Greenland rare earths play shows strong magnetic pull for Eclipse
www.smh.com.au
February 20, 2026 at 5:54 AM
February 20, 2026 at 5:51 AM
Speedy recovery to you, Becky with the Good Hair.
February 20, 2026 at 5:48 AM
Speedy recovery to you, Becky with the Good Hair.
February 20, 2026 at 5:47 AM
+“The amendments also remove 24 entities and one individual from the Syria Regulations to reduce barriers to economic activity and to enable transactions with state-affiliated entities in key sectors critical to Syria’s recovery,” Anand said in a statement. The Cradle news....
February 20, 2026 at 5:47 AM
+“The amendments also remove 24 entities and one individual from the Syria Regulations to reduce barriers to economic activity and to enable transactions with state-affiliated entities in key sectors critical to Syria’s recovery,” Anand said in a statement. The Cradle news....
I'm so sorry to hear this. I wish her the best in her treatment and recovery.
Thank goodness her sister is there for her.
Thank goodness her sister is there for her.
February 20, 2026 at 5:45 AM
I'm so sorry to hear this. I wish her the best in her treatment and recovery.
Thank goodness her sister is there for her.
Thank goodness her sister is there for her.
Re-Centering Rights, Recovery, And Evidence In US Mental Health Policy www.healthaffairs.org/content/fore...
Re-Centering Rights, Recovery, And Evidence In US Mental Health Policy | Health Affairs Forefront
We propose a rights-based, recovery-oriented approach for mental health reform—one that both protects civil liberties and invests in the structural supports necessary for recovery.
www.healthaffairs.org
February 20, 2026 at 5:44 AM
Re-Centering Rights, Recovery, And Evidence In US Mental Health Policy www.healthaffairs.org/content/fore...
February 20, 2026 at 5:43 AM
It's a big deal when trauma survivors get the hang of using humor to get us through dark moments, instead of using it to kick the sh*t out of ourselves.
Humor is an underappreciated trauma recovery tool that our abusers often taught us to use as a weapon for self-harm.
Humor is an underappreciated trauma recovery tool that our abusers often taught us to use as a weapon for self-harm.
February 20, 2026 at 5:41 AM
It's a big deal when trauma survivors get the hang of using humor to get us through dark moments, instead of using it to kick the sh*t out of ourselves.
Humor is an underappreciated trauma recovery tool that our abusers often taught us to use as a weapon for self-harm.
Humor is an underappreciated trauma recovery tool that our abusers often taught us to use as a weapon for self-harm.
My own trauma & addiction recovery shifted when I realized that it's less about the big, dramatic moment or realizations than it is about handling the stupid everyday stuff w/ perspective & compassion.
Realistic recovery prioritizes daily & hourly self-talk & decisions.
Realistic recovery prioritizes daily & hourly self-talk & decisions.
February 20, 2026 at 5:40 AM
My own trauma & addiction recovery shifted when I realized that it's less about the big, dramatic moment or realizations than it is about handling the stupid everyday stuff w/ perspective & compassion.
Realistic recovery prioritizes daily & hourly self-talk & decisions.
Realistic recovery prioritizes daily & hourly self-talk & decisions.
Trauma recovery is not a goal that we succeed or fail at. It's an everyday commitment to being realistic & compassionate w/ our wounds & needs-- one we reaffirm every morning, because we deserve to have more influence over our lives than our abusers, bullies, or past.
February 20, 2026 at 5:40 AM
Trauma recovery is not a goal that we succeed or fail at. It's an everyday commitment to being realistic & compassionate w/ our wounds & needs-- one we reaffirm every morning, because we deserve to have more influence over our lives than our abusers, bullies, or past.
February 20, 2026 at 5:39 AM
Something many trauma survivors have in common is, we don't feel like we were born into a "tribe" (not any tribe that we want to be part of, anyway). Recovery often involves finding &/or creating our "tribe," by being real & expressive about things our culture tends to deny.
February 20, 2026 at 5:39 AM
Something many trauma survivors have in common is, we don't feel like we were born into a "tribe" (not any tribe that we want to be part of, anyway). Recovery often involves finding &/or creating our "tribe," by being real & expressive about things our culture tends to deny.
Your mileage may vary, but for me thinking about trauma recovery as this list of sh*t I "have" to think about & do for the rest of my life gets overwhelming real fast.
Maybe don't try to handle the next 20 years today. Focus on your goals for this day, this hour, this minute.
Maybe don't try to handle the next 20 years today. Focus on your goals for this day, this hour, this minute.
February 20, 2026 at 5:38 AM
Your mileage may vary, but for me thinking about trauma recovery as this list of sh*t I "have" to think about & do for the rest of my life gets overwhelming real fast.
Maybe don't try to handle the next 20 years today. Focus on your goals for this day, this hour, this minute.
Maybe don't try to handle the next 20 years today. Focus on your goals for this day, this hour, this minute.
Compassionate care is a measurable factor in patient satisfaction and recovery outcomes. Studies indicate that patients who perceive high levels of empathy from their healthcare providers report up to 30% higher. Click here to know more about #DrwendellBulmerTampafl drwendellbulmerscholarship.com
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drwendellbulmerscholarship.com
February 20, 2026 at 5:38 AM
Compassionate care is a measurable factor in patient satisfaction and recovery outcomes. Studies indicate that patients who perceive high levels of empathy from their healthcare providers report up to 30% higher. Click here to know more about #DrwendellBulmerTampafl drwendellbulmerscholarship.com
One of hardest parts of trauma & addition recovery for me was my emphatic conviction that I should't HAVE to change, God dammit, they're the ones who suck, why is it on ME to heal, huh?
That anger was valid. It deserved to exist.
And, making decisions from it kept me stuck.
That anger was valid. It deserved to exist.
And, making decisions from it kept me stuck.
February 20, 2026 at 5:36 AM
One of hardest parts of trauma & addition recovery for me was my emphatic conviction that I should't HAVE to change, God dammit, they're the ones who suck, why is it on ME to heal, huh?
That anger was valid. It deserved to exist.
And, making decisions from it kept me stuck.
That anger was valid. It deserved to exist.
And, making decisions from it kept me stuck.
February 20, 2026 at 5:35 AM
My tracker decided not to record my very long walk today, and I'm more annoyed than I probably should be lol.
Although I'm more annoyed about not having an accurate metric of my load for recovery purposes than that my effort wasn't noticed by technology.
Although I'm more annoyed about not having an accurate metric of my load for recovery purposes than that my effort wasn't noticed by technology.
February 20, 2026 at 5:35 AM
My tracker decided not to record my very long walk today, and I'm more annoyed than I probably should be lol.
Although I'm more annoyed about not having an accurate metric of my load for recovery purposes than that my effort wasn't noticed by technology.
Although I'm more annoyed about not having an accurate metric of my load for recovery purposes than that my effort wasn't noticed by technology.
Talk to your neurologist. I would say before because the Linac has possibility of creating neural damage that might be unnecessary if the Botox works. But you would need to talk with the neurologist about whether failed Botox would have any effect on the procedure/recovery.
February 20, 2026 at 5:34 AM
Talk to your neurologist. I would say before because the Linac has possibility of creating neural damage that might be unnecessary if the Botox works. But you would need to talk with the neurologist about whether failed Botox would have any effect on the procedure/recovery.
![EFTA01416838 | EFTA01416944
Page 34
2016 U.S. Dist. LEXIS 97188, *
estimate, a reasonable percentage-of-recovery fee in this case would be
between
$1,900,000 and $13,500,000. The fee award sought by counsel and the lodestars
calculated under Defendants' proposed New York-Philadelphia mean and fourth quartile
billing rates all fall within this range.
For the second factor, the Court incorporates its Girsh analysis of Class
member
objections and notes that no Class members have objected to the proposed
Class Counsel
award. This factor weighs in [*81] favor of fee approval. The Court also
finds that the third
and fourth, and sixth Gunter factors weigh in favor of approving a fee award
within the
ranges sought by Plaintiffs and Defendants. As discussed, Class Counsel
spent 5,100
hours over three years litigating this case, survived a motion to dismiss,
and obtained a fair
and reasonable settlement in a complex, multi-state consumer class action
involving
uncertain legal issues. The fifth Gunter factor -- risk of nonpayment -weighs in favor of
approving the award sought by Plaintiffs because Class Counsel undertook
this case on a
contingency basis and accepted the potential risk of non-payment. ECF No. 86
at 20-21.
Finally, with regard to the sixth Gunter factor, the $2,230,000 award sought
by Plaintiffs
and Defendants' proposed lodestar calculations are similar to awards
approved in similar
cases. See, e.g, Henderson v. Volvo Cars of N. Am., LLC, 2013 U.S. Dist.
LEXIS 46291,
2013 WL 1192479, at *13 (D.N.J. Mar. 22, 2013) (approving award of
$3,000,000 in
attorneys' fees in class action providing class members with reimbursements
and warranty
extensions in connection with alleged defects in automobile transmission
systems);
O'Keefe v. Mercedes-Benz USA, LLC, 214 F.R.D. 266, 304 (E.D. Pa. 2003)
(approving
award of $4,896,783 in attorneys' fees in class action involving allegedly
defective rear liftgate
hatch in [*82] automobiles).
4. The expenses sought by Plaintiffs are](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:ndjyym3ihrqu3g25gdztefrv/bafkreifbsvduehlpiz2mvenv6ei5c4f6y2fyg4p47jsxg526hwegdvw3xy@jpeg)
February 20, 2026 at 5:32 AM
![EFTA01416838 | EFTA01416942
Page 33
2016 U.S. Dist. LEXIS 97188, *
proposed lodestar and billable hour totals based on 96.5 hours [*78] from
Mr. Yanchunis at $900 per hour and 32.7 hours from
Ms. Ponder at $150 per hour, for a firm lodestar of $91,755. See ECF No.
96-9 Ex. 2.
As discussed, the Court may apply a multiplier to the lodestar "to account
for the
contingent nature or risk involved in a particular case and the quality of
the attorney's
work." Rite Aid, 396 F.3d at 306. The multiplier "need not fall within any
pre-defined range,
provided that the District Court's analysis justifies the award," id., but
courts "routinely find
in complex class action cases that a lodestar multiplier between one and
four is fair and
reasonable." Saini, 2015 U.S. Dist. LEXIS 66242, 2015 WL 2448846, at *16
(approving
multipliers of 1.09 and 1.13); see also Boone v. City of Philadelphia, 668
F. Supp. 2d 693,
714-15 (E.D. Pa. 2009) (approving multiplier of 2.3); McCoy v. Health Net,
Inc., 569 F.
Supp. 2d 448, 479 (D.N.J. 2008) (approving multiplier of 2.3). Because
Plaintiffs report a
total of $133,358.30 in expenses, ECF No. 86 at 2, the portion of the total
$2,320,000
award attributable to attorneys' fees alone is $2,186,641.70. The lodestar
multiplier for
Defendants' proposed mean rate fee, obtained by dividing $2,186,641.70 by
$1,917,673.40, would be approximately 1.14. This multiplier falls well
within the range
approved by courts in this Circuit for complex, multi-state cases such as
this one.
3. The percentage cross-check supports an award in [*79] the lodestar range
Having determined a range of attorneys' fees under a lodestar analysis, the
Court now
cross-checks this analysis using the percentage-of-recovery method. See Ins.
Brokerage,
579 F.3d at 280; Saini, 2015 U.S. Dist. LEXIS 66242, 2015 WL 2448846, at *16
(performing percentage-of-recovery cross-check after adopting lodestar
method to award
attorneys' fees).
The Third Circuit has identified a non-exhaustive list of](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:ndjyym3ihrqu3g25gdztefrv/bafkreid3kwqbez2vcftngrvjk3gu4lip7tw4dq5t4wklx4sc57siv22nki@jpeg)
February 20, 2026 at 5:32 AM
![EFTA01416838 | EFTA01416928
Page 26
2016 U.S. Dist. LEXIS 97188, *
A. Legal standard
Federal Rule of Civil Procedure 23(h) provides that, "[i]n a certified class
action, the court
may award reasonable attorney's fees that are authorized by law or by the
parties'
agreement." Fed. R. Civ. P. 23(h). A "thorough judicial [*59] review of fee
applications is
required in all class action settlements." GM Truck Prods., 55 F.3d at 819.
"Determining an
appropriate award is not an exact science," and the "facts of each
individual case drive the
amount of any award." In re AremisSoft Corp. Sec. Litig. ("AremisSoft"), 210
F.R.D. 109,
128 (D.N.J. 2002).
The Third Circuit has established two methods for evaluating an award of
attorneys' fees:
the percentage-of-recovery method, which involves giving attorneys a portion
of the total
damages awarded to plaintiffs, and the lodestar method, which involves
multiplying the
number of hours reasonably worked on a case by the reasonable billing rate
for the
services. Prudential, 148 F.3d at 333; In re Ins. Brokerage Antitrust Litig.
("Ins.
Brokerage"), 579 F.3d 241, 280 (3d Cir. 2009) (citing In re Rite Aid Corp.
Sec. Litig. ("Rite
Aid"), 396 F.3d 294, 302 (3d Cir. 2005)). The percentage-of-recovery method
is generally
favored in cases involving a common fund, while the lodestar method "is more
commonly
applied in statutory fee-shifting cases." Prudential, 148 F.3d at 333. The
lodestar method
may also be applied "in cases where the nature of the recovery does not
allow the
determination of the settlement's value necessary for application of the
percentage-of recovery
method." Id. (citing GM Truck Prods., 55 F.3d at 821). The court should
perform a
"cross-check" by comparing the fee award [*60] calculated under the chosen
method with
the award calculated under the alternative method. Ins. Brokerage, 579 F.3d
at 280 (citing
Rite Aid, 396 F.3d at 300).
"The party seeking attorney's fees has the burden to prove that its request
for](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:ndjyym3ihrqu3g25gdztefrv/bafkreicm45zaof5urt7wsoq3eudgpvhtdtz6gc5dxp4yzbjhondszw3fd4@jpeg)
February 20, 2026 at 5:32 AM
![EFTA01416838 | EFTA01416924
Page 24
2016 U.S. Dist. LEXIS 97188, *
to pay any more than what . . . class members are entitled to under the
theories of liability
that existed at the time the settlement was reached." Warfarin Sodium, 391 F.3d. at 538.
Here, as Plaintiffs state, "Defendants operate a successful, well-known,
multi-national
automobile business." ECF No. 28. Even if all 5,310 Class members who
submitted claims
were entitled to the maximum claim amounts for each type of repair,
replacement, or sale,
the total amount of the settlement would likely be insignificant when
compared with
Defendants' total revenues. This factor does not favor approval of the
settlement.
7. Girsh factors eight and nine: the reasonableness of the settlement in
light of the
best recovery [*54] and all the attendant risks of litigation
The final two Girsh factors "test two sides of the same coin: reasonableness
in light of the
best possible recovery and reasonableness in light of the risks the parties
would face if the
case went to trial." Warfarin Sodium, 391 F.3d at 538 (citing Prudential,
148 F.3d at 322).
The Court determines "whether the settlement represents a good value for a
weak case or
a poor value for a strong case." Id. In cases where plaintiffs seek
primarily monetary relief,
"the present value of the damages plaintiffs would likely recover if
successful,
appropriately discounted for the risk of not prevailing, should be compared
with the amount
of the proposed settlement." Id. (quoting Prudential, 148 F.3d at 322).
In the second amended complaint, Plaintiffs seek, among other things, (a) an
order
requiring Defendants to notify Class members of the alleged timing chain
tensioner defect
and to repair the defect or reimburse Class members for the repairs; (b) an
injunction
requiring Defendants to stop refusing to repair the defect, at no charge;
(c) an award to
Plaintiffs and Class members of compensatory, exemplary, and/or statutory
damages; and
(d) an award of](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:ndjyym3ihrqu3g25gdztefrv/bafkreiea4hhdeuhmv5m6hkzbwwqukxnkyylvgzomvonl4mt77g6ze7ozsu@jpeg)
February 20, 2026 at 5:31 AM