Electronically Filed by Superior Court of California, County of Orange, 06/04/2021 05:21:00 PM.

30-2019-01044791-CU-OE-CXC - ROA # 144 - DAVID H. YAMASAKI, Clerk of the Court By Olga Lopez, Deputy Clerk.

1 DAVID YEREMIAN & ASSOCIATES, INC.

DAVID YEREMIAN (SBN 226337)
2 David@yeremianlaw.com
3 535 N. Brand Blvd., Suite 705
Glendale, California 91203
4 Telephone: (818) 230-8380
Facsimile: (818) 230-0308
5
6 UNITED EMPLOYEES LAW GROUP, PC
WALTER HAINES (SBN 71075)
7 whaines@uelg.com
5500 Bolsa Ave., Suite 201
8
Huntington Beach, CA 92649
9 Telephone: (310) 652-2242

10 Attorneys for Plaintiffs’ Miguel Haro Lopez and Jesus

Rodriguez, on behalf of themselves and all others
11
similarly situated
12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
FOR THE COUNTY OF ORANGE
14
15
MIGUEL HARO LOPEZ, an individual, on Case No.: 30-2019-01044791-CU-OE-CXC
16 behalf of himself and others similarly
situated, CLASS ACTION
17
18 Plaintiff, Assigned for All Purposes To:
Hon. Kirk Nakamura
19 vs. Dept.: CX-103
20
TW SERVICES, INC., a California RESPONSE TO OSC BY ATTORNEY
21 corporation; and DOES 1 through 50, DAVID YEREMIAN
inclusive,
22
Defendants. Complaint Filed: January 16, 2019
23 PAGA Complaint Filed: March 22, 2019
24 First Amended Complaint: July 8, 2020
OSC hearing: June 10, 2021
25
26
27
28

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Case No.: 30-2019-01044791
 1 I, DAVID YEREMIAN, declare as follows:
2 1. I am an attorney duly licensed to practice law before all courts in the state of
3 California, the United States District Courts for the Central, Southern, Eastern and Northern Districts
4 of California, and the Ninth Circuit Court of Appeals. I have personal knowledge of the facts herein,
5 and if called as a witness I could and would competently testify to them.
6 2. I am the managing attorney and President of the law firm of David Yeremian &
7 Associates, Inc., counsel of record for Plaintiffs Miguel Haro Lopez and Jesus Rodriguez (“Plaintiffs”
8 or “Class Representatives”) on behalf of themselves and others similarly situated employees of
9 Defendant TW SERVICES, INC. (“Defendant”). The Court preliminarily approved the parties’
10 settlement agreement and our firm and co-counsel to serve as Class counsel, and we filed our motion
11 for final approval and supporting documents. Those documents included my Declaration in support of
12 final approval and in support of Class counsel’s requested fees and costs.
13 3. The Court did not grant final approval, and instead set the present OSC to address
14 concerns with the number of attorneys’ hours I summarized from our detailed time and task
15 summaries. As the declarant and managing partner of our firm, I accept full responsibility for those
16 events and the filings the Court has understandably questioned. I respectfully provide the following
17 details of my background and experience, and explanation of my understanding and perception of the
18 events at issue as they transpired, with the hope this perspective will provide further clarifying insight
19 for the Court’s consideration.
20 4. I graduated in 2001 from the University of California Los Angeles School of Law and
21 was admitted to practice law in California in 2003. Since 2007, I have represented employees in
22 discrimination, harassment, and wage and hour matters. A substantial portion of my practice consists
23 of representing employees in class action and PAGA matters against their current and/or former
24 employers. I have been appointed as class counsel in over 150 class actions in both state and federal
25 courts since 2007.
26 5. Plaintiffs jointly retained my co-counsel, Walter Haines of United Employees Law
27 Group, Inc., and my firm to serve as attorneys of record in this matter, and we have faithfully done so.
28 I have served as the attorney for Plaintiffs and the preliminarily approved Class with primary

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Case No.: 30-2019-01044791
 1 responsibility for the prosecution of Plaintiffs’ claims on behalf of the putative Class against
2 Defendant. In my capacity as managing attorney for our firm, I am also responsible for supervising the
3 work of the attorneys and paralegals assigned to the cases under me. Starting in March of 2020 and
4 continuing through today, my staff, including attorneys, have been working remotely.
5 6. I assigned Jason Rothman as the responsible attorney for the day to day prosecution of
6 our Class-wide and PAGA claims against Defendant in this action. I have worked with him closely to
7 shepherd this action from intake through preliminary and now final approval of the settlement. Mr.
8 Rothman is no longer employed at our firm, but his departure was not related to the issues at hand and
9 he will be appearing before the Court to answer any questions it may have.
10 7. After a year of litigation, we were able to negotiate a class settlement with Defendant
11 for Two Million Five Hundred Thousand Dollars for wage and hour violations and PAGA penalties.
12 Our firm had been retained on a contingency basis, which meant we would not receive any payment
13 for our firm’s legal work unless and until this matter settled. The motion for final approval and my
14 supporting declaration requested up to $833,333.33 in attorney’s fees (to be paid to both David
15 Yeremian & Associates, Inc. and United Employees Law Group, Inc.), and up to $30,000 in costs
16 incurred on behalf of the Class. This request for an award of contingent fees was calculated as a
17 percentage of the common fund the settlement has created for the Class members.
18 8. Mr. Rothman worked under my supervision on this matter until April 9, 2021, his last
19 day of work with our law firm. Mr. Rothman was responsible for making direct time entries into our
20 firm’s timekeeping system on a daily basis. Prior to his departure, he also drafted the Motion for Final
21 Approval of Class Action Settlement, Attorneys’ Fees and Expenses (“Motion for Final Approval”)
22 and prepared the supporting documents, including the declarations. This included the Detailed Time
23 and Task Summary for Jason Rothman, which was attached as Exhibit C to my declaration filed in
24 support of the Motion for Final Approval. Leading up to Mr. Rothman’s last days at the firm, I
25 reminded him to ensure he recorded all his time worked on all his cases.
26 9. I underestimated the amount of work that Mr. Rothman’s separation on April 9th would
27 create for me. At the time of his departure, Mr. Rothman was handling over 50 files, the vast majority
28 of which are litigated matters. I assumed direct responsibility for all of those files immediately upon

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Case No.: 30-2019-01044791
 1 Mr. Rothman’s departure, in addition to managing the entire firm and supervising all of our cases. I
2 am working hard to manage the extra work load, as we are still down one attorney.
3 10. Indeed, on April 9th, Mr. Rothman’s last day, and April 13th, the day before the Motion
4 for Final Approval was filed, I was in all day mediations. I spent several hours finalizing my time
5 summary and finalized my declaration and the motion with the lodestar figures. However, I neglected
6 to review the time summary Mr. Rothman prepared. I typically meet with the associate who prepares
7 any significant motion and supporting documents prior to filing to review for accuracy and discuss any
8 potential issues. In this case, not only had Mr. Rothman already left the firm (rendering him
9 unavailable for such a meeting), but I was inundated with two mediations and the transfer of
10 responsibilities for over 50 cases. I therefore did not follow my normal practice and neglected to
11 review Mr. Rothman’s time summary prior to attaching it to my declaration. I instead simply
12 referenced the total number of hours Mr. Rothman included in his summary.
13 11. I recognize that paragraph 15 of my declaration inaccurately stated Mr. Rothman had
14 “expended 357 hours” on the case when, as our firm’s own timekeeping records confirm he recorded a
15 total of 160.7 hours. In executing my declaration on April 14, 2021, I was unaware that Mr. Rothman’s
16 actual billed time was 160.7 hours, instead of the 357 hours he reported on the Time and Task
17 Summary. I did not see his footnote on page 6 of his Detailed Time and Task Summary, nor did I
18 review his contemporaneous time records. I accept full responsibility for my oversight, and
19 respectfully request the Court’s understanding and perspective of the events and circumstances that led
20 to it. Had I reviewed these documents to ensure an accurate reporting of hours to the Court, I would
21 have contacted Mr. Rothman to address his notation on the last page of his summary to specifically
22 clarify the total hours he actually worked.
23 12. The error I committed in summarizing the firm’s hours in my declaration is particularly
24 embarrassing for me because prioritizing my personal integrity, and the integrity of my firm, have
25 always been at the core of my practice. I strive to represent my clients zealously, and diligently seek to
26 provide courts and opposing counsel with accurate information. I should have been more careful
27 before I signed my declaration on April 14, 2021, and accept full responsibility for any inaccuracies in
28 it.

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Case No.: 30-2019-01044791
 1 13. While I accept it does not excuse my oversight, I most certainly had no intention to
2 mislead the Court by providing inaccurate information in support of the requested fees. I have no
3 understanding of why Mr. Rothman made a notation about summarizing more hours than he actually
4 worked, as I have never instructed or even implied to any firm attorney that they should exaggerate
5 their billable hours in an effort to reduce any requested multiplier in a lodestar cross-check. I can only
6 surmise that Mr. Rothman misunderstood my instructions for him to calculate the lodestar and
7 multiplier in this case. I would never knowingly compromise my integrity or the firm’s integrity by
8 inflating hours we have invested in an action. It would serve no purpose to make the requested fee
9 award more or less reasonable in a contingency setting, where fees are requested and drawn from the
10 common benefit we create for the employees we represent.
11 14. I understand it is within this Court’s discretion to determine the appropriate award of
12 attorneys’ fees in this matter, including considering and weighing the implications of our misstated
13 hours. Whatever the Court decides, I respectfully submit the Class Members should not be punished by
14 my oversight in a way that would further delay granting final approval to the preliminarily approved
15 settlement and distributing funds to them. Any requested attorneys’ fees not approved by the Court will
16 remain part of the Net Settlement Fund, and the funds will be distributed to the Class Members in
17 accordance with the Settlement when it is finally approved. See Joint Stipulation of Settlement
18 attached as Exhibit A to the Declaration of David Yeremian in support of Motion for Final Approval,
19 7:7-9.
20 15. I summarized my time spent on this matter in Exhibit B to my declaration in support of
21 Final Approval. These time entries were not contemporaneously recorded. However, in accordance
22 with accepted procedures, hours reported as a lodestar cross-check of the reasonableness of a
23 contingency fee may be estimated and supported with testimony. “As this court has held, ‘An
24 attorney’s testimony as to the number of hours worked is sufficient evidence to support an award of
25 attorney fees, even in the absence of detailed time records.’” Mardirossian & Associates, Inc. v. Ersoff
26 (2007) 153 Cal.App.4th 257, 269 (quoting Steiny & Co. v. California Electric Supply Co. (2000) 79
27 Cal.App.4th 285, 293). “[P]recise calculations are not required; fair approximations based on personal
28 knowledge will suffice.” Id. Therefore, the document I attached as Exhibit B to my declaration at issue

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 1 is a true and accurate estimate of the hours I expended on the prosecution of this matter. In creating
2 Exhibit B, I reviewed every task, calendar entry, pleading and briefing (including drafts), email, phone
3 log, note and document produced in the file. I have been personally involved in this case since the
4 original intake was completed in 2018. Based on my personal day-to-day involvement, my notes and
5 records, my emails, and the entire contents of the file I reviewed, I certify under penalty of perjury that
6 I expended at least 190 hours of my time on this file since September of 2018. I submit that my
7 estimate of 190 hours expended is reasonable and non-duplicative of time and effort expended by other
8 members of my staff, especially considering the 33 months this case has been pending, the issues
9 involved in this case, the procedural history, and the analysis and due diligence required to prosecute
10 this action.
11 16. Attached as Exhibit A to this Declaration is a true and correct copy of Mr. Rothman’s
12 detailed time records for this matter. Mr. Rothman started working on this case in December 2018. His
13 last timekeeping entries were on April 5, 2021. These time records were contemporaneously recorded
14 by Mr. Rothman, and he then created his time and task summary document at issue from them. These
15 entries reflect a total of 160.7 hours. I believe, though I am not certain, Mr. Rothman had duplicated
16 some of these entries into another timekeeping system at various points during the litigation and later
17 mistakenly added them together thereby double counting a handful of entries in arriving at his
18 conclusion of 185.38 hours worked on this case. In addition, there are 3 entries in his contemporaneous
19 time log that were incomplete as to the time expended. These were entries for drafting a PAGA-only
20 complaint on 3/19/19, checking a tentative ruling and subsequent conferences with myself and
21 opposing counsel re: same on 9/10/20, and for finalizing my supplemental declaration in support of
22 preliminary approval and revision of the class notice on 9/18/20. I do not know why there were no time
23 entries made for these events but I do know they were completed as I reviewed or participated in each
24 event personally. I estimate that these 3 events totaled several hours of work for Mr. Rothman but I do
25 not have personal knowledge of the exact time he invested. I also surmise that there are several hours
26 unaccounted for in these time records that Mr. Rothman expended on this matter.
27 17. Other members of my staff (besides Mr. Rothman and myself) also invested additional
28 time on behalf of the Class in this matter. This includes numerous hours by our firm’s legal assistants

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Case No.: 30-2019-01044791
 1 which are not contemporaneously tracked. However, Alvin B. Lindsay, the senior associate attorney at
2 my firm, incurred at least 11.1 hours on this case working under my direction. Please see Exhibit B for
3 his true and correct time records. These time entries were contemporaneously recorded. Mr. Lindsay
4 has over 18 years of experience litigating complex matters including class actions, is a graduate of the
5 United States Military Academy at West Point, has served as an Army Officer for 10 years in the
6 Corps of Engineers, and graduated from Whittier Law School. His applicable rate for lodestar purposes
7 is $700/hr.
8 18. Under the circumstances, I respectfully request that the Court discharge the Order to
9 Show Cause and not impose monetary sanctions against me (or Messrs. Rothman and Haines) for
10 filing an erroneous declaration. Mr. Haines certainly had no hand in my declaration or Mr. Rothman’s
11 time. Ultimately the declaration at issue was signed by me alone putting the responsibility for its
12 contents on my shoulders. I did not intend to mislead the Court by signing my declaration in support of
13 the Motion for Final Approval on April 14, 2021. While I acknowledge there is no excuse for my
14 oversight, I submit the internal contradictions contained in the documents I filed with the court were an
15 unfortunate by-product of the immense pressure of losing an associate attorney, handling the transfer
16 of a heavy case load, and managing several mediations all in a short period of time. I did not
17 knowingly or intentionally violate a court order or attempt to inflate the hours reported to the Court. I
18 simply neglected to carefully review the attachment to my declaration and clarify it with my associate
19 as I should have done.
20 19. I understand the serious nature of this OSC. I assure the Court I have learned that
21 careful review of motion papers (including my declaration and all attachments) is non-negotiable prior
22 to filing, especially when signing under penalty of perjury. I recognize I should have requested a
23 continuance of the deadline rather than rush a filing and will ensure I replace recognition with action in
24 any similar future instances. I have also learned that I need to more closely supervise my team in the
25 preparation of court filings and will remain dedicated to doing so. Nevertheless, I respectfully submit
26 that my mistakes should not penalize the Class Members and final approval of the settlement is
27 appropriate and should be granted regardless of what the Court orders in terms of attorneys’ fees and
28 sanctions.

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Case No.: 30-2019-01044791
 1 20. I recognize and respect the Court’s discretion to impose sanctions despite any
2 explanation I have provided. Should the Court determine to exercise that discretion, I respectfully
3 request that any sanctions it might impose be limited to only me as the supervising attorney. I am the
4 one who signed the declaration under penalty of perjury. It was my responsibility as the owner of the
5 firm, the appointed class counsel and the declarant to ensure its accuracy. Mr. Rothman did not submit
6 a declaration or otherwise certify his time to the Court. He did not sign a declaration under penalty of
7 perjury. And Mr. Haines, as previously stated, had no hand in my declaration or my firm’s time entries.
8 I declare under penalty of perjury that this foregoing declaration is true and correct and this
9 declaration is executed on this 4th day of June 2021 in Glendale, California.
10
11
By: __________________________________
12
David Yeremian
13 Attorneys for Plaintiffs Miguel Haro Lopez
and Jesus Rodriguez, and all others similarly
14 situated
15
16
17
18
19
20
21
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23
24
25
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EXHIBIT A
Date Matter
12/7/2018 Haro v TW Services
12/11/2018 Haro v TW Services
1/2/2019 Haro v TW Services
1/2/2019 Haro v TW Services
1/11/2019 Haro v TW Services
1/11/2019 Haro v TW Services
1/14/2019 Haro v TW Services
1/15/2019 Haro v TW Services
1/15/2019 Haro v TW Services
1/16/2019 Haro v TW Services
1/16/2019 Haro v TW Services
1/22/2019 Haro v TW Services
3/5/2019 Haro v TW Services
3/7/2019 Haro v TW Services
3/18/2019 Haro v TW Services
3/19/2019 Haro v TW Services
4/2/2019 Haro v TW Services
4/2/2019 Haro v TW Services
4/2/2019 Haro v TW Services
4/5/2019 Haro v TW Services
4/5/2019 Haro v TW Services
4/8/2019 Haro v TW Services
Time Descrption
0.6 Briefly review case; follow up with client to schedule a time to
discuss his matter further
0.2 Follow up discussion with Mr. Yeremian regarding the status of the
th case and not being able to contact our client
0.7 Prepare for meeting with client to go over further intake questions
1.8 Attend meeting with client regarding client documents and further
intake questions
1.3 Review client file and draft/transcribe notes regarding
conversation with client as to further intake
1.8 Begin drafting of the Complaint
4.1 Continue Drafting of the Complaint
4.3 Finish drafting of the Complaint; multiple email correspondences
with Mr. Yeremian regarding further revisions to be made
0.5 Begin drafting of the LWDA letter regarding PAGA
0.2 Further revisions to the Complaint; email correspondence to Ms.
Bermudes for filing
3.6 Finish drafting LWDA letter regarding PAGA; email correspondence
to Mr. Yeremian for his review
0.3 Email correspondence between client regarding status of the case;
the filed Complaint; and potential additional allegations he would
like to bring forward
0.7 Prepare for and attend telephonic meet and confer with opposing
counsel regarding the status of the case and informal discovery v
formal discovery
1.7 Draft Joint Case Management Statement; email correspondece to
opposing counsel regarding the same and informal discovery
requests
0.2 Email correspondence to opposing counsel regarding status of the
Joint Report
Draft of PAGA only Complaint
0.9 Prepare for and attend Initial Status Conference
0.6 Prepare Notice of Further Status Conference; email
correspondence to Ms. Bermudes for service and filing
0.6 Email correspondences to Ms. Rizzuto regarding the status of the
hearing and meeting and conferring in advance of the Joint Report
filing deadline
0.4 Prepare for and attend meet and confer with opposing counsel in
advance of Joint Report deadline
0.6 Telephone conversation with client regarding expanding
allegations to different facilities and reaching out to other potential
class members for declarations
0.9 Prepare a draft of a Joint Report in advance of the Case
Management Conference; email correspondence to opposing
counsel for the same
Date Matter
4/8/2019 Haro v TW Services
4/8/2019 Haro v TW Services
4/10/2019 Haro v TW Services
4/10/2019 Haro v TW Services
4/10/2019 Haro v TW Services
4/17/2019 Haro v TW Services
4/17/2019 Haro v TW Services
4/17/2019 Haro v TW Services
4/17/2019 Haro v TW Services
4/17/2019 Haro v TW Services
4/17/2019 Haro v TW Services
4/18/2019 Haro v TW Services
4/22/2019 Haro v TW Services
4/23/2019 Haro v TW Services
4/24/2019 Haro v TW Services
4/24/2019 Haro v TW Services
4/25/2019 Haro v TW Services
5/1/2019 Haro v TW Services
5/6/2019 Haro v TW Services
5/7/2019 Haro v TW Services
Time Descrption
1.1 Research into TW Services multiple locations and our clients
statements that he worked at multiple locations, though they are
under a different name
0.2 Email correspondence to Mr. Yeremian regarding our clients
wrongful termination claim
0.3 Review of Defendant's portion of the Joint Report; email
correspondence to Ms. Bermudes for filing of the same
0.2 Email correspondence to Defendant regarding needing to obtain
Defendant's portion of the Joint Report by noon for filing
0.3 Email correspondence to Ms. Rizzuto regarding ESI data points in
an alternative to going the Belaire-West notice route for informal
discovery in advance of mediation
0.8 Prepare for and attend Further Case Management hearing
0.3 Telephone conversation with Ms. Rizzuto regarding Plaintiff's last
day of employment; follow up email correspondence with Walter
Haines office regarding the same; attempt to reach client regarding
the same to further discuss
0.4 Draft Belaire-West Notice
0.2 Email correspondence to client regarding his last day of
employment with Defendants and any other potential class
members we could contact regarding his case
0.3 Email correspondence to Ms. Rizzuto regarding the Belaire-West
Notice and mediator suggestions, along with a representative
sample to proceed informally
0.6 Begin drafting discovery requests
0.4 Further drafting of Plaintiff's discovery requests to Defendant
0.5 Telephone conversation with Ms. Rizzuto regarding the PAGA
element and early mediation; follow up with Mr. Yeremian
regarding the same
0.5 Continue working on propounding discovery, Request for
Admissions (Set 1)
2.8 Finish drafting Discovery to propound to Defendant (Form
Interrogatories General/Employment), Special Interrogatories,
Request for Admission, Request for Production; email
correspondence to Ms. Bermudes for service of the same
0.4 Prepare Notice of Deposition of PMK; email correspondence to Ms.
Bermudes regarding service of the same
0.6 Draft Deposition Notice regarding Human Resources; email
correspondence to Ms. Bermudes of service of the same
0.3 Telephone conversation with client and potential new class
representative regarding allegations in the Complaint
0.2 Email correspondence with Ms. Rizzuto regarding deposition dates
and the status of the Belaire-West Notice
0.4 Multiple email correspondences with Ms. Rizzuto regarding CPT
Group as the Belaire-West administrator
Date Matter
5/8/2019 Haro v TW Services
5/10/2019 Haro v TW Services
5/14/2019 Haro v TW Services
5/15/2019 Haro v TW Services
5/15/2019 Haro v TW Services
5/17/2019 Haro v TW Services
5/20/2019 Haro v TW Services
5/20/2019 Haro v TW Services
5/21/2019 Haro v TW Services
5/21/2019 Haro v TW Services
5/22/2019 Haro v TW Services
5/24/2019 Haro v TW Services
5/24/2019 Haro v TW Services
5/24/2019 Haro v TW Services
5/30/2019 Haro v TW Services
6/25/2019 Haro v TW Services
6/26/2019 Haro v TW Services
6/27/2019 Haro v TW Services
6/27/2019 Haro v TW Services
7/2/2019 Haro v TW Services
7/8/2019 Haro v TW Services
Time Descrption
0.4 Reach out to Sean at ILYM regarding a quote for the Belaire-West
Notice; follow up with Ms. Rizzuto regarding the same
0.3 Discussion with Mr. Yeremian regarding status of case
0.7 Prepare Request for Production of Documents (Set 2); email
correspondence to Ms. Zambrano for service of the same
0.2 Review deadlines
0.2 Attempt to reach client to further discuss the case with him
0.3 Email correspondence to Farrah from ILYM regarding the Belaire
west notice and its circulation
0.3 Email correspondences with opposing counsel regarding the status
of deposition dates and PMK availability
0.2 Review of the finalized Belaire West Notice as sent by ILYM; follow
up regarding the same
0.2 Email correspondence between Ms. Rizzuto regarding the class list
being served to ILYM on this date
0.3 Email correspondences between Mr. Becker regarding PMK
deposition date availability; follow up with Mr. Yeremian regarding
the same
0.2 Follow up with Mr. Yeremian regarding deposition date availability
0.6 Telephonic meet and confer with opposing counsel (Mr. Becker)
regarding the status of the case, discovery, and scheduling an in-
person meet and confer to discuss early mediation options
0.6 Multiple email correspondences with Mr. Becker regarding staying
the current case until the in-person meet and confer and an
agreement to not seek class waivers and arbitration agreements in
the meantime
0.3 Detailed email correspondence to Mr. Yeremian regarding the
conversation between Mr. Becker and Mr. Rothman and
proceeding with the case
0.2 Email correspondence with Mr. Yeremian regarding mediation
schedule
0.3 Email correspondence to client regarding status of case
0.3 Review case in advance of meet and confer with opposing counsel
1.1 Prepare for meet and confer with Mr. Becker; review client
documents and documents responsive to discovery requests
1.6 Meeting with Mr. Becker regarding regarding the case, explaining
the different work sites and pay structures, and mediation
0.6 Draft Joint Report in Advance of Further Status Conference; email
correspondence to opposing counsel for their review of the same
for filing
0.5 Further revisions to the Joint Report; multiple email
correspondences with Ms. Rizzuto regarding the Joint Report
Date Matter
8/16/2019 Haro v TW Services
8/21/2019 Haro v TW Services
8/21/2019 Haro v TW Services
8/22/2019 Haro v TW Services
9/4/2019 Haro v TW Services
9/9/2019 Haro v TW Services
9/9/2019 Haro v TW Services
9/12/2019 Haro v TW Services
9/19/2019 Haro v TW Services
9/19/2019 Haro v TW Services
9/20/2019 Haro v TW Services
10/17/2019 Haro v TW Services
10/17/2019 Haro v TW Services
10/21/2019 Haro v TW Services
10/21/2019 Haro v TW Services
10/23/2019 Haro v TW Services
10/24/2019 Haro v TW Services
10/25/2019 Haro v TW Services
10/25/2019 Haro v TW Services
10/28/2019 Haro v TW Services
10/28/2019 Haro v TW Services
10/28/2019 Haro v TW Services
Time Descrption
0.3 Email correspondence to Mr. Becker regarding scheduling a time to
meet and confer over Defendants informatl discovery production;
follow up regarding the same
0.2 Email correspondence to Mr. Becker regarding rescheduling the
conference call to later in the day
0.4 Meet and confer with Mr. Becker regarding creating an informal
discovery timeline and data to be produced
0.4 Review Defendants informal discovery production; follow up email
correspondence with Mr. Yeremian to discuss
0.3 Brief review of informal document data points
0.5 Review informal document production produced thus far;
discussion with Mr. Yeremian regarding the same and data analysis
0.2 Email correspondence to Mr. Becker regarding the informal
document production and scheduling a time to discuss further
0.7 Prepare for and attend telephonic meet and confer over informal
discovery in advance of mediation
0.2 Review of potential sub classes
0.4 Email correspondence to Mr. Becker regarding informal echange of
information in advance of mediation along with data points to be
dicussed; further discussion on potential sub classes
0.5 Prepare for and attend telephonic meet and confer with opposing
counsel regarding informal discovery in advanc eof mediation
0.3 Follow up email correspondences with Mr. Becker regarding the
informal discovery already produced and too be produced
0.7 Review of a portion of Defendants informal discovery in advance of
mediation
0.3 Multiple email correspondences between Mr. Rothman and Mr.
Becker regarding Informal Discovery in advance of mediation and
Defendants production of such
0.6 Brief review of Defendants informal discovery produced so far
0.4 Email correspondence to Mr. Gorlick regarding data analysis and
review
0.5 Telephone conversation with Mr. Gorlick regarding data analysis
and theories of case; follow up regarding the same
0.5 Multiple telephone conversations with Mr. Gorlick regarding data
analysis
0.4 Telephone conversation with Mr. Becker regarding informal
discovery and additional data points necessary for mediation
0.3 Discussion with Mr. Yeremian regarding mediation
0.3 Further telephonic call with Mr. Gorlick regarding data analysis
0.2 Email correspondence to Mr. Becker regarding additional data
necessary for in advance of mediation
Date Matter
10/28/2019 Haro v TW Services
10/28/2019 Haro v TW Services
10/28/2019 Haro v TW Services
10/28/2019 Haro v TW Services
10/29/2019 Haro v TW Services
10/29/2019 Haro v TW Services
10/29/2019 Haro v TW Services
10/29/2019 Haro v TW Services
10/30/2019 Haro v TW Services
10/31/2019 Haro v TW Services
10/31/2019 Haro v TW Services
10/31/2019 Haro v TW Services
11/1/2019 Haro v TW Services
11/4/2019 Haro v TW Services
11/5/2019 Haro v TW Services
11/6/2019 Haro v TW Services
11/7/2019 Haro v TW Services
11/7/2019 Haro v TW Services
11/8/2019 Haro v TW Services
11/8/2019 Haro v TW Services
11/11/2019 Haro v TW Services
11/11/2019 Haro v TW Services
11/12/2019 Haro v TW Services
11/12/2019 Haro v TW Services
Time Descrption
1.7 Begin researching regarding drafting of Mediation Brief and claims
of Defendants
0.3 Further e-mail correspondence between Mr. Becker regarding
additional data necessary for mediation
0.2 Review Mr. Gorlick's damage analysis
0.6 Begin drafting mediation brief
0.3 Follow up email correspondence to Mr. Gorlick regarding aspects
of the damage model and exposure
1.3 Continue researching In re Certified Tires and similar cases, along
with legal theories
4.1 Continue drafting mediation brief and pulling exhibits
0.2 Email correspondence to Ms. Khayat regarding status of mediation
brief
0.8 Further review and revisions to mediation brief
2.3 Further review and revisions to mediation brief; follow up with Ms.
Khayat regarding the same
0.4 Multiple email correspondences to Mr. Yeremian regarding
mediation brief and factual analysis
1.0 Multiple discussions with Mr. Yeremian regarding mediation brief
and fatcual allegations
1.3 Multiple email correspondeces to Mr. Yeremian regarding
upcoming mediation and factual and legal allegations
1.6 Additional review and research into allegations being brought
fourth in Plaintiff's mediation brief
1.4 Continue researching legal theories of the case; multiple email
correspondences to Mr. Yeremian regarding the same
0.7 Further legal research into the claims alleged in the Complaint for
purposes of mediation
0.4 Multiple attempts to reach client; follow up with Walter Haines
office regarding the same
0.3 Additional research for purposes of mediation
0.3 Multiple email correspondences between client to schedule a time
to discuss his case further
0.4 Telephone conversation with client regarding status of settlement
at mediation
0.4 Review Memorandum of Understanding; contact client regarding
the same document being sent to him for his electronic signature
0.2 Review Mr. Haro's email regarding the memorandum of
understanding
0.4 Multiple email correspondences with client to schedule a time to
meet and confer over settlement
3.9 Prepare for and attend in-person meet and confer with client over
settlement; follow up with Mr. Yeremian regarding the same
Date Matter
11/13/2019 Haro v TW Services
11/13/2019 Haro v TW Services
11/13/2019 Haro v TW Services
11/13/2019 Haro v TW Services
11/15/2019 Haro v TW Services
11/18/2019 Haro v TW Services
11/18/2019 Haro v TW Services
11/19/2019 Haro v TW Services
11/19/2019 Haro v TW Services
11/20/2019 Haro v TW Services
11/21/2019 Haro v TW Services
11/21/2019 Haro v TW Services
11/22/2019 Haro v TW Services
11/22/2019 Haro v TW Services
11/22/2019 Haro v TW Services
11/25/2019 Haro v TW Services
11/25/2019 Haro v TW Services
11/26/2019 Haro v TW Services
11/27/2019 Haro v TW Services
11/27/2019 Haro v TW Services
12/2/2019 Haro v TW Services
12/2/2019 Haro v TW Services
12/2/2019 Haro v TW Services
12/2/2019 Haro v TW Services
12/2/2019 Haro v TW Services
Time Descrption
0.3 Discussion with Mr. Yeremian regarding Mr. Haro's signature on
the memorandum of understanding
0.2 Telephone message to Mr. Haro, following up on yesterdays in-
person meeting regarding settlement
0.2 Email correspondence to Mr. Haro, following up on yesterday's in-
person meeting regarding settlement
0.4 Further attempts to contact client by e-mail and telephone
0.2 Discussion with Mr. Yeremian regarding status of case
0.3 Multiple discussions with Mr. Yeremian regarding status of Mr.
Haro as an adequate class representative
0.3 Email correspondences to client regarding client file
0.3 Discussion with Mr. Yeremian regarding clients adequacy as a class
representative
0.8 Research class representative adequacy requirements
0.5 Draft letter correspondence to client regarding class representative
duties
0.2 Multiple email correspondences to client regarding his request for
his client file
0.3 Email correspondence to Ms. Bermudes regarding documents to
copy for Mr. Haro regarding his request for his personnel file
0.7 Meeting with Mr. Yeremian regarding regarding clients request for
file and obtaining a new class repesentative
0.9 Further discussions with Mr. Yeremian regarding Mr. Haro, the
class action settlement, and clients fiduciary duty to the class
0.3 Multiple email correspondeces with Mr. Haro regarding status of in
person meet and confer over settlement
0.4 Multiple email correspondences with client regarding status of
settlement and his clientele file
0.3 Telephone conversation with Mr. Yeremian regarding status of
settlement
0.2 Email correspondence to Mr. Haro regarding status of signature on
Memorandum of Understanding and his request to review client
file
0.3 Further email correspondences with client regarding meeting and
conferring in person about his case
0.3 Prepare for meeting and confer with client
0.5 Draft Joint Report; email correspondence to Mr. Becker regarding
his review of the same
0.2 Further Review of Joint Report; email correspondence to Ms.
Bermudes for filing of of the same
0.2 Review signed Memorandum of Understanding; email
correspondence to Mr. Becker regarding the same
0.3 Draft Joint Report regarding the PAGA action; email
correspondence to Mr. Becker for his review of the same
0.2 Discussion with Mr. Yeremian regarding clients follow up questions
pertaining to his client file
Date Matter
12/2/2019 Haro v TW Services
12/3/2019 Haro v TW Services
12/3/2019 Haro v TW Services
12/9/2019 Haro v TW Services
12/10/2019 Haro v TW Services
12/13/2019 Haro v TW Services
12/13/2019 Haro v TW Services
12/16/2019 Haro v TW Services
12/16/2019 Haro v TW Services
12/17/2019 Haro v TW Services
12/18/2019 Haro v TW Services
12/31/2019 Haro v TW Services
1/2/2020 Haro v TW Services
1/2/2020 Haro v TW Services
1/3/2020 Haro v TW Services
1/6/2020 Haro v TW Services
1/15/2020 Haro v TW Services
1/17/2020 Haro v TW Services
1/20/2020 Haro v TW Services
1/29/2020 Haro v TW Services
2/5/2020 Haro v TW Services
3/12/2020 Haro v TW Services
Time Descrption
0.2 Discussion with Mr. Yeremian regarding the long form settlement
agreement
0.3 Discussion with Ms. Zambrano regarding Mr. Haro's email and
status as class representative
0.5 Review Mr. Haro's email; follow up email correspondence to Mr.
Yeremian regarding the same
0.2 Review Mr. Yeremian e-mail to Mr. Haro regarding the status of
settlement
0.2 Review Mr. Yeremian's email correspondence to Mr. Haro; follow
up discussion with Mr. Yeremian regarding the same
0.4 Discussion with Mr. Yeremian regarding drafting of the Stipulation
regarding Settlement
0.6 Begin drafting Stipulation regarding settlement
1.9 Draft Stipulation regarding Settlement; email correspondence to
Mr. Yeremian regarding his review of the same
0.3 Multiple email correspondences to CPT Claims Administrator
regarding preparing a bid for the claims administration process
1.6 Further revisions to Stipulation regarding Settlement and Class
Notice; email correspondence to Mr. Yeremian regarding the same
for his review
0.2 Review CPT Bid; follow up email correspondence regarding the
same
0.6 Review revisions to Long Form Settlement Agreement; follow up
email correspondence to Mr. Lindsay regarding the same
0.4 Multiple email correspondences with ILYM Group regarding
competitive bids for claim administration; review of bids
0.9 Further review and revisions to the Stipulation regarding
settlement; email correspondence to Mr. Becker for his review of
the same
0.2 Email correspondence with CPt Claims administrator regarding
status of case
0.3 Email correspondence to Mr. Becker regarding claims
administration and monthly payments to the Qualified Settlement
Fund
0.3 Begin reviewing Mr. Beckers revisions to the Stipulation regarding
Settlement
0.4 Review and revisions to the Stipulation regarding settlement; email
correspondence to Mr. Becker regarding the same for his review
0.2 Further revisions to the Stipulation regarding Settlement; email
correspondence to Mr. Yeremian regarding the same
0.3 Prepare email to Mr. Haro regarding Stipulation of Settlement for
Mr. Yeremian's delivery
0.3 Meet and confer with Mr. Yeremian regarding status of case
0.2 Email correspondences with Mr. Yeremian regarding proceeding
with a motion to name a new class representative
Date Matter
3/16/2020 Haro v TW Services
3/17/2020 Haro v TW Services
3/18/2020 Haro v TW Services
3/18/2020 Haro v TW Services
3/19/2020 Haro v TW Services
3/19/2020 Haro v TW Services
3/19/2020 Haro v TW Services
3/26/2020 Haro v TW Services
3/30/2020 Haro v TW Services
4/3/2020 Haro v TW Services
4/21/2020 Haro v TW Services
4/22/2020 Haro v TW Services
4/22/2020 Haro v TW Services
4/22/2020 Haro v TW Services
5/6/2020 Haro v TW Services
5/13/2020 Haro v TW Services
5/13/2020 Haro v TW Services
5/18/2020 Haro v TW Services
5/20/2020 Haro v TW Services
7/7/2020 Haro v TW Services
7/8/2020 Haro v TW Services
7/8/2020 Haro v TW Services
7/8/2020 Haro v TW Services
Time Descrption
0.2 Email correspondence to Mr. Yeremian regarding status of
Stipulation re new class representitive and settlement
0.4 Draft Joint Report in advance of Further Status Conference; email
correspondence to Mr. Becker regarding the same for his review
0.2 Review Court Order regarding continuance of hearing; email
correspondence to Ms. Bermudes regarding the same
0.2 Revise and prepare First Amended Complaint
1.9 Draft First Amended Complaint
1.2 Draft Joint Stipulation to Amend the Complaint, Draft Proposed
Order regarding the same
0.6 Revise Long Form Settlement Agreement
0.2 Telephonic discussion with Ms. Bermudes regarding status of case
1.1 Draft LWDA Letter regarding PAGA for Jesus Rodriguez; multiple
follow up email correspondences to Mr. Yeremian regarding the
same
0.4 Revisions to Jesus Rodriguez PAGA notice letter; email
correspondeence to Ms. Bermudes for filing of the same
0.2 Telephonic discussion with Mr. Yeremian regarding the case
0.2 Email correspondence with Mr. Becker regarding the case and the
further status conference amid COVID-19
0.6 Review and revise Stipulation regarding First Amended Complaint
0.4 Review Proposed Order and First Amended Complaint
0.6 Revise First Amended Complaint to include PAGA Allegations
0.2 Email correspondence to Mr. Yeremian regarding the Stipulation
and [Proposed] Order to file a First Amended Complaint
0.2 Review Stipulation to file Second Amended Complaint; email
correspondence to Mr. Beecker regarding the same for his
signature
0.3 Review [Proposed Order; email correspondence to Mr. Yeremian
regarding the same for his review
0.2 Email correspondnce with Ms. Bermudes regarding rescheduling of
hearings for the Class Action and PAGA matter
0.2 Email correspondence to Ms. Bermudes regarding filing of ther
First Amended Complaint
0.2 Follow up with Ms. Bermudes regarding filing of the First Amended
Complaint
1.9 Review case files and e-mails; draft letter to Mr. Haro regarding
Stipulation for Settlement and duties of class representative; follow
up with Mr. Yeremian regarding the same
0.4 Review and revisions to Stipulation regarding Settlement; follow up
with Mr. Yeremian and Mr. Becker regarding the same
Date Matter
7/8/2020 Haro v TW Services
7/10/2020 Haro v TW Services
7/13/2020 Haro v TW Services
7/13/2020 Haro v TW Services
7/15/2020 Haro v TW Services
7/20/2020 Haro v TW Services
7/20/2020 Haro v TW Services
7/27/2020 Haro v TW Services
7/30/2020 Haro v TW Services
8/3/2020 Haro v TW Services
8/5/2020 Haro v TW Services
8/6/2020 Haro v TW Services
8/7/2020 Haro v TW Services
8/10/2020 Haro v TW Services
8/11/2020 Haro v TW Services
8/12/2020 Haro v TW Services
8/13/2020 Haro v TW Services
8/14/2020 Haro v TW Services
8/17/2020 Haro v TW Services
8/17/2020 Haro v TW Services
8/18/2020 Haro v TW Services
Time Descrption
0.3 Furtehr review of client files; follow up email correspondence to
Mr. Yeremian regarding the same
0.5 Draft Joint Report; follow up email correspondence to Mr. Becker
regarding the same and scheduling a time to meet and confer
0.4 Multiple email correspondences with M. Yeremian regarding
timeline of events
0.2 Review and revise Joint Report; email correspondence to Ms.
Bermudes to file the same
0.4 Review revisions to Settlement Agreement; finalize and circulate to
all counsel for signatures
0.6 Prepare for and attend Further Status Conference
0.3 Email and telephonic conference with Mr. Becker regarding the
class period; follow up email with Mr. Yeremian regarding the
same
0.3 Email correspondence to Ms. Bermudes regarding the case; follow
up with Mr. Yeremian regarding the same
0.3 Review letter to Mr. Rodriguez; follow up email correspondence to
Mr. Yeremian regarding the same
1.9 Research Preliminary Approval before Judge Claster; begin
drtafting Preliminary Approval regarding the same
3.8 Continue researching and drafting Preliminary Approval moving
papers; follow up with Mr. Becker regarding the same
4.2 Continue drafting Preliminary approval moving papers
5.1 Finish drafting Preliminary Approval and all supporting motions;
email correspondence to Mr. Yeremian regarding the same for his
review
0.3 Review preliminary approval Declaration of David Yeremian
0.3 Telephonic conversation with Mr. Yeremian regarding Preliminary
Approval; follow up with Mr. Becker regarding the same
1.1 Review changes; further revisions to Preliminary Approval moving
paperes
2.8 Further revisions to Preliminary Approval and all supporting
moving documents; follow up with mr. Yeremian regarding the
same
1.3 Further review and revisions to Preliminary Approval; follow up
with Mr. Yeremian and Mr. Becker regarding the same before filing
0.3 Email correspondence to Ms. Bermudes regarding scheduling a
hearing date for Preliminary Approval moving papers
0.3 Email correspondences with Ms. Bermudes regarding Preliminary
Approval moving paperes; follow telephonic conversation
regarding thee same
0.2 Email correspondence to Mr. Yeremian regarding the status of
Preliminary Approval hearing
Date Matter
8/26/2020 Haro v TW Services
8/28/2020 Haro v TW Services
9/9/2020 Haro v TW Services
9/10/2020 Haro v TW Services
9/11/2020 Haro v TW Services
9/14/2020 Haro v TW Services
9/14/2020 Haro v TW Services
9/15/2020 Haro v TW Services
9/16/2020 Haro v TW Services
9/16/2020 Haro v TW Services
9/17/2020 Haro v TW Services
9/18/2020 Haro v TW Services
9/23/2020 Haro v TW Services
9/23/2020 Haro v TW Services
9/23/2020 Haro v TW Services
9/25/2020 Haro v TW Services
9/25/2020 Haro v TW Services
10/6/2020 Haro v TW Services
10/6/2020 Haro v TW Services
10/7/2020 Haro v TW Services
10/22/2020 Haro v TW Services
Time Descrption
0.4 Draft Joint Report in advance of Further Status conference; follow
up with Mr. Becker regarding the same
0.2 Finalize Joint Report; email correspondence to Ms. Bermudes
regarding the same for filing
0.2 Check tenative ruling regarding preliminary approval; follow up
with Mr. Yeremian regarding the same
Check docket for Tentative; review tentative; follow up with Mr.
Yeremian and Mr. Becker regarding the same
0.2 Email correspondence to Mr. Yeremian regarding Supplemental
Briefing regarding Preliminary Approval
0.2 Review courts preliminary approval tentative
1.1 Telephonic meet and confer with Mr. Yeremian regarding the
court's preliminary approval tentative
0.2 Telephonic meet and confer with Mr. Yeremian regarding status of
the case and Preliminary Approval revisions
0.3 Communication with Mr. Yeremian regarding revising the
settlement agreement and changign the cy pres award designation
3.7 Begin working on Supplememtal Preliminary Approval briefing
0.3 Continuing working on Supplemental Preliminary Approval briefing
Finish Drafting Supplemental Declaration of David Yeremian in
Support of Preliminary Approval; further revisions to the Class
Notice regarding the same
0.3 Telephonic conversation with Mr. Gorlick regarding expert
declaration in support of Preliminary Approval
0.3 Draft template for Declaration of Mr. Gorlick; follow up with Mr.
Gorlick regarding the same
0.2 Review Mr. Gorlicks Declaration
0.3 Telephonic conference with Mr. Yeremian regarding further
revisions to the supplemental briefing in support of preliminary
approval
2.2 Further revisions to the Supplemental briefing in support of
preliminary approval; follow up with Mr. Yeremian regarding the
same
0.2 Telephonic discussion with Ms. Bermudes regarding signatures on
the settlement agreement
0.2 Review settlement agreement; send to Mr. Becker for signatures
4.2 Further review and revisions to Supplemental preliminary approval
moving papers, all exhibits, and [proposed] order; follow up
telephone conversation with Ms. Bermudes regarding the same for
filing
0.3 Review court's tentative regarding preliminary approval
Date Matter
10/22/2020 Haro v TW Services
11/2/2020 Haro v TW Services
11/9/2020 Haro v TW Services
11/10/2020 Haro v TW Services
11/20/2020 Haro v TW Services
11/30/2020 Haro v TW Services
12/2/2020 Haro v TW Services
12/2/2020 Haro v TW Services
12/15/2020 Haro v TW Services
12/15/2020 Haro v TW Services
12/15/2020 Haro v TW Services
12/28/2020 Haro v TW Services
1/4/2021 Haro v TW Services
1/18/2021 Haro v TW Services
1/20/2021 Haro v TW Services
3/31/2021 Haro v TW Services
3/31/2021 Haro v TW Services
3/31/2021 Haro v TW Services
4/5/2021 Haro v TW Services
4/5/2021 Haro v TW Services
Time Descrption
0.6 Draft Declaration of David Yeremian in Support of Preliminary
Approval; follow up email correspondence to Mr. Yeremian
regarding the same
0.3 Multiple email correspondences with Mr. Yeremian regarding
Supplemental Preliminary Approval revisisions
0.3 Review and revise the Declaration of David Yeremian in Support of
Preliminary Approval; email correspondence to Mr. Becker
regarding the same
0.3 Review and finalize Decalration of David Yeremian in Support of
Preliminary Approval; follow up with Msl Bermudes regarding filing
of the same
0.5 Review and revise [Proposed] Order regardng Preliminary
Approval; email correspondence to Ms. Bermudes regarding filing
of the same
0.2 Email correspondence to Ms. Bermudes regarding filing a proof of
service for the proposed order approvbing preliminary approval of
the settlement
0.2 Email correspondence to Mr. Becker and Sean from ILYm regarding
claim administration process
0.2 Email correspondence to claim administration regarding class
notice materials
0.2 check docket regarding signed order for Preliminary Approval
0.3 Email correspondences to ILYM Claim Administration regardinfg
the signed order, class notice, and settlement agreement
0.2 Review mailing timeline; follow up email correspondence to claim
administrator regarding the same
0.3 Review of Class Notice before mailing; follow up email
correspondence to claim administrator regarding suggested
changes to be made
0.2 Review Opt Out Notice and Notice of Settlement Share; follow up
with claim administrator regarding the same
0.9 Review timeline of case through receipt and filing of Complaint
along with statute of limitations; multiple follow up's with Mr.
Yeremian regarding the same
0.2 Review court order regarding new hearing date; follow up with Ms.
Bermudes regarding the same
0.6 Draft Declaration of Walter Haines ISO Final Approval; follow up
with Walter Haines regarding the same
0.3 Review and revise claim administration declaration ISO Final
Approval; follow up with Claim Administrator regarding the same
1.1 Begin drafting Final Approval moving papers
0.3 Email correspondence to claim administrator regarding their
declaration in support of final approval
0.3 Conversation with Mr. Yeremian regarding Final Approval
Date Matter Time Descrption
4/5/2021 Haro v TW Services 1.8 Draft Declaration of David Yeremian in support of Final Approval

4/5/2021 Haro v TW Services 0.9 Draft [Proposed] Order and Judgment Granting Final Approval
Total 160.7
EXHIBIT B
 Report for HARO v. TW SERVICES, INC. File No: 2759

From 1/01/18 to 5/18/21

BillingDateRaw User Explanation Hours
11/19/2019 Alvin Lindsay Conduct research on replacement 1.6
representative and right to discover.
Compile case law and summarize
and draft correspondence to
regarding same.

12/30/2019 Alvin Lindsay Review settlement agreement and 1.7

draft revisions expanding cy pres
and addressing QSF and timing of
payments into it by Defendant. Draft
correspondence to DY and JR
regarding same and review
responses - draft further revisions to
Settlement.
12/31/2019 Alvin Lindsay Further revisions to the Settlement 1.9
Agreement following review of e-mail
from DY and draft correspondence
regarding same and status of
revisions. Draft correspondence to
JR summarizing revisions and
recommendations. Address
settlement administrator and st

01/06/2020 Alvin Lindsay Confer and correspond with JR re: 0.8

administration and not to exceed
quotation and rounded number and
timing of setting up QSF. Address
interest on QSF and how to address
and allocate and draft e-mail to JR.
03/13/2020 Alvin Lindsay Correspond and confer with JR 0.6
regarding stipulation for leave to file
amended complaint and suggestions
for language and samples, and
confer regarding enhancements for
PAGA vs. Class settlements. Draft e-
mail to JR.
04/24/2020 Alvin Lindsay Review file docs and Complaint 2.1
filings and LWDA letters for Haro
class and Haro PAGA and
Rodriguez PAGA and draft
stipulation and order for
consolidating classes and adding
class rep. Draft correspondence to
DY regarding same and
11/03/2020 Alvin Lindsay Research pleadings and settlement 2.4
and draft revisions to further
supplemental declaration of DY
addressing court tentative ruling
regarding further items to address.
Confer and correspond with JR and
DY regarding same.
Total 11.1
 1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES:
3 I am employed in the aforesaid county, State of California; I am over the age of 18 years
and not a party to the within action; my business address is 535 N. Brand, Blvd. Suite 705,
4 Glendale CA 91203.
5 On June 4, 2021, I served the foregoing: RESPONSE TO OSC BY ATTORNEY
DAVID YEREMIAN on Interested Parties in this action by placing a true copy thereof,
6 enclosed in a sealed envelope, addressed as follows:
7 Erick J. Becker, P.C.
ebecker@cwlawyers.com
8 Noura K. Rizzuto
nrizzuto@cwlawyers.com
9 Ed Farrell
Efarrell@cwlawyers.com
10 CUMMINS & WHITE, LLP
2424 S.E. Bristol Street, Suite 300
11 Newport Beach, CA 92660-0764
12 [ ] (BY MAIL) I placed such envelope with postage thereon fully paid in the United States
mail at Glendale, California. I am “readily familiar” with this firm’s practice of collecting and
13 processing correspondence for mailing. It is deposited with U.S. Postal Service on that same day
in the ordinary course of business. I am aware that on motion of party served, service is
14 presumed invalid if postal cancellation date or postage meter date is more than 1 day after date of
deposit for mailing in affidavit.
15
[X] (ONLY BY ELECTRONIC TRANSMISSION) Only by e-mailing the document(s) to
16 the persons at the e-mail address(es) listed based on notice provided on June 4, 2021 that, during
the Coronavirus (COVID-19) pandemic, this office will be working remotely, not able to send
17 physical mail as usual, and is therefore using only electronic mail. No electronic message or other
indication that the transmission was unsuccessful was received within a reasonable time after the
18 transmission.
19 [ ] (BY OVERNIGHT DELIVERY) I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the persons at the address above. I
20 placed the envelope or package for collection and overnight delivery at an office or a regularly
utilized drop box of the overnight delivery carrier.
21
[X] (STATE) I certify (or declare) under penalty of perjury under the laws of the State of
22 California that the foregoing is true and correct.
23 Executed on June 4, 2021, at Glendale, California.
24

25 Natalia Bermudes

26
27

28