On March 01, 2019 a
Party Statement
was filed
involving a dispute between
Ramirez, Joe,
and
Apex Logistics, Llca California Limited Liability Company,
Class 8 Truck Repair, Llc A California Limited Liability Company,
Hartwick And Hand Llc A Nevada Limited Liability Company,
Hartwick & Hand, Inc A California Corporation,
Ramirez, Joe,
for Employment-Other-Complex
in the District Court of San Bernardino County.
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ORLGINAL
SOLOUKI SAVOY, LLP
i L E D
“UPERIOR
a COURT OF CALIFORNiA
Shoham J. Solouki, Esq. [SBN 278538] COUNTY OF SAN BERNARDINO
SAN BFRNADWNO DISTRICT
Grant Joseph Savoy, Esq. [SBN 284077]
316 W. 2nd Street, suite1200
NOV 09 2021
Los Angeles, CA 90012
Telephone: (2 l 3) 8 14-4940
Attomeysfor Plainnfland the Proposed Class
BY #2
ALI-IE
S&W
CERVANTES, DEPUTY
FAX \OOOQON
BY
10
11
12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
FOR THE COUNTY OF SAN BENARDINO
14
15
16
JOE RAMIREZ, on behalf ofhimself and all Case: CIVDSl906586
17 other similarly situated non-exempt former
and current employees;
18 Assigned for All Purposes:
Hon. David Cohn
Plaintiff,
19 Dept. $26
vs.
20
CLASS ACTION
21 HARTWICK AND HAND LLC, a Nevada
Limited Liability Company; HARTWICK &
22 HAND, Inc., a California Corporation;
DECLARATION OF CAROLE
APEX LOGISTICS, LLC, a California THOMPSON ON BEHALF OF CPT
23
Limited Liability Company; CLASS 8
GROUP, INC. THE SETTLEMENT
TRUCK REPAIR, LLC, a California ADMINISTRATOR
24
Limited Liability Company; and DOES 1
Date: November 16, 2021
25 through 10 inclusive
Time: 10:00 AM
Dept: 826
26 Defendants.
27
28
Page 1
DECLARATION 0F CAROLE THOMPSON 0N BEHALF 0F CPI GROUP, INc, THE SETTLEMENT ADMNISTRATOR
l
DECLARATION OF CAROLE THOMPSON
I,Carole Thompson, hereby declare:
1. I am employed as a Supervising Case Manager by CPT Group, Inc. (“CPT”), the Court-
appointed Settlement Administrator for Ramirez v.Hartwick and Hand LLC, et al.I am authorized to
VQUIAWN
make this declaration on behalfof CPT. As the Supervising Case Manager for this settlement, Ihave
personal knowledge ofthe information provided herein, and if called as a witness, I could and would
accurately testify thereto.
m 2. Isubmit this declaration to update CPT’s previous declaration dated July 12, 2021
3. The total number ofworkweeks members
for all class collectively (for the pulpose of
10 calculating the receiptby each class member for each week worked) is8,879.
11 4. The total number of aggrieved employees for thePAGA settlement is 63.
12 5. The total number of pay-periods for all aggn'eved employees collectively during the
13 PAGA period is 5,591.
14
15 Ideclare under penalty ofperjury under the laws ofthe State of California that the foregoing is
16 true and conect. Executed this 5th day ofNovember, 2021 at Irvine, California.
17
18
Carole Thompson
19
20
21
22
23
24
25
26
27
28
Page 2
DECLARANON 0F CAROLE THOMPSON 0N BEHALF 0F CPT GROUF, INC. THE SETTLEMENT ADMINISTRATOR
Document Filed Date
November 09, 2021
Case Filing Date
March 01, 2019
Category
Employment-Other-Complex
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ORLGINAL SOLOUKI SAVOY, LLP i L E D “UPERIOR a COURT OF CALIFORNiA Shoham J. Solouki, Esq. [SBN 278538] COUNTY OF SAN BERNARDINO SAN BFRNADWNO DISTRICT Grant Joseph Savoy, Esq. [SBN 284077] 316 W. 2nd Street, suite1200 NOV 09 2021 Los Angeles, CA 90012 Telephone: (2 l 3) 8 14-4940 Attomeysfor Plainnfland the Proposed Class BY #2 ALI-IE S&W CERVANTES, DEPUTY FAX \OOOQON BY 10 11 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA 13 FOR THE COUNTY OF SAN BENARDINO 14 15 16 JOE RAMIREZ, on behalf ofhimself and all Case: CIVDSl906586 17 other similarly situated non-exempt former and current employees; 18 Assigned for All Purposes: Hon. David Cohn Plaintiff, 19 Dept. $26 vs. 20 CLASS ACTION 21 HARTWICK AND HAND LLC, a Nevada Limited Liability Company; HARTWICK & 22 HAND, Inc., a California Corporation; DECLARATION OF CAROLE APEX LOGISTICS, LLC, a California THOMPSON ON BEHALF OF CPT 23 Limited Liability Company; CLASS 8 GROUP, INC. THE SETTLEMENT TRUCK REPAIR, LLC, a California ADMINISTRATOR 24 Limited Liability Company; and DOES 1 Date: November 16, 2021 25 through 10 inclusive Time: 10:00 AM Dept: 826 26 Defendants. 27 28 Page 1 DECLARATION 0F CAROLE THOMPSON 0N BEHALF 0F CPI GROUP, INc, THE SETTLEMENT ADMNISTRATOR l DECLARATION OF CAROLE THOMPSON I,Carole Thompson, hereby declare: 1. I am employed as a Supervising Case Manager by CPT Group, Inc. (“CPT”), the Court- appointed Settlement Administrator for Ramirez v.Hartwick and Hand LLC, et al.I am authorized to VQUIAWN make this declaration on behalfof CPT. As the Supervising Case Manager for this settlement, Ihave personal knowledge ofthe information provided herein, and if called as a witness, I could and would accurately testify thereto. m 2. Isubmit this declaration to update CPT’s previous declaration dated July 12, 2021 3. The total number ofworkweeks members for all class collectively (for the pulpose of 10 calculating the receiptby each class member for each week worked) is8,879. 11 4. The total number of aggrieved employees for thePAGA settlement is 63. 12 5. The total number of pay-periods for all aggn'eved employees collectively during the 13 PAGA period is 5,591. 14 15 Ideclare under penalty ofperjury under the laws ofthe State of California that the foregoing is 16 true and conect. Executed this 5th day ofNovember, 2021 at Irvine, California. 17 18 Carole Thompson 19 20 21 22 23 24 25 26 27 28 Page 2 DECLARANON 0F CAROLE THOMPSON 0N BEHALF 0F CPT GROUF, INC. THE SETTLEMENT ADMINISTRATOR