FAT Brands Inc.

12/12/2025 | Press release | Archived content

Reply Memorandum of Law in Further Support of Plaintiffs’ Application for Approval of the Settlement, an Award of Attorneys’ Fees and Expenses, and Plaintiffs’ Service Award

EFiled: Dec 12 2025 11:51AM EST
Transaction ID 77986542
Case No. Multi-Case
IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
JAMES HARRIS AND THE
ESTATE OF ADAM
CHRISTOPHER VIGNOLA,
derivatively on behalf of FAT
BRANDS INC.,

Plaintiffs,

v.

SQUIRE JUNGER, JAMES
NEUHAUSER, EDWARD H. RENSI,
ANDREW A. WIEDERHORN, FOG
CUTTER HOLDINGS, LLC, and FOG
CUTTER CAPITAL GROUP, INC.,

Defendants,

-and-

FAT BRANDS INC., a Delaware Corporation,

Nominal Defendant. 		C.A. No. 2021-0511-NAC
JAMES HARRIS AND THE
ESTATE OF ADAM
CHRISTOPHER VIGNOLA,
derivatively on behalf of FAT
BRANDS INC.,

Plaintiffs,

v.

SQUIRE JUNGER, JAMES
NEUHAUSER, EDWARD H. RENSI,
ANDREW A. WIEDERHORN, FOG
CUTTER HOLDINGS, LLC, and FOG
CUTTER CAPITAL GROUP, INC.,

Defendants,

-and-

FAT BRANDS INC., a Delaware Corporation,

Nominal Defendant. 		C.A. No. 2022-0254-NAC
REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF
PLAINTIFFS' APPLICATION FOR APPROVAL OF THE SETTLEMENT,
AN AWARD OF ATTORNEYS' FEES AND EXPENSES, AND
PLAINTIFFS' SERVICE AWARD

On October 9, 2025, the Notice of Pendency of Settlement of Derivative Actions (the "Notice") was disseminated pursuant to, and in accordance with, the Scheduling Order approved by the Court on September 18, 2025.1 In response to the Notice, no objections to the proposed Settlement or award of attorneys' fees and expenses have been filed with the Court or received by counsel for the parties to the above-captioned Actions. This further supports approval of the Settlement, and the requested award of attorneys' fees and expenses. Spen v. Andrews Grp., Inc., 1992 WL 127512, at *1 (Del. Ch. June 5, 1992).

Because there is no opposition to the proposed Settlement or the requested award of attorneys' fees and expenses, Plaintiffs will not submit an extensive reply brief. Rather, for the reasons stated in Plaintiffs' Application for Approval of the Settlement, an Award of Attorneys' Fees and Expenses, and Plaintiffs' Service Award, Plaintiffs again respectfully request that the Court grant final approval of the proposed Settlement, the requested award of attorneys' fees and expenses, and the requested service awards.

1 Aff. Regarding Not. of Settlement, ¶¶3-7, Trans. ID 77838321 (Dec. 4, 2025).

Of Counsel:
Donald J. Enright
Brian Stewart
LEVI & KORSINSKY, LLP
1101 Vermont Avenue, Suite 800
Washington, DC 20005
(202) 524-4290

D. Seamus Kaskela
Adrienne Bell
KASKELA LAW LLC
18 Campus Boulevard, Suite 100
Newtown Square, PA 19073
(484) 258-1585
ASHBY & GEDDES
/s/ Stephen E. Jenkins
Stephen E. Jenkins (#2152)
500 Delaware Avenue, 8th Floor
Wilmington, DE 19801
(302) 654-1888
[email protected]

Attorneys for Plaintiffs
Dated: December 12, 2025
Words: 189 / 8,000
Multi-Case Filing Detail: The document above has been filed
and/or served into multiple cases, see the details below including
the case number and name.
Transaction Details
Court: DE Court of Chancery Civil Action Transaction ID: 77986542
Document Type: Reply
Document Title: Reply Memorandum of
Law in Further Support of Plaintiffs'
Application for Approval of the Settlement,
an Award of Attorneys' Fees and
Expenses, and Plaintiffs' Service Award
Submitted Date & Time: Dec 12 2025 11:51AM
Case Details
Case Number Case Name
2021-0511-NAC STAYED 5-2-25/CONF/ James Harris v. Squire Junger
2022-0254-NAC STAYED (2/7/2024) CONF ORDER James Harris v. Squire Junger
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