Preview
1 Shaun Setareh (SBN 204514)
shaun@setarehlaw.com
2 ELECTRONICALLY
Thomas Segal (SBN 222791)
thomas@setarehlaw.com F I L E D
3 Jose Maria D. Paitno, Jr. (SBN 270194) Superior Court of California,
County of San Francisco
jose@setarehlaw.com
4 Tyson Gibb (SBN 339154) 06/03/2022
tyson@setarehlaw.com Clerk of the Court
BY: EDNALEEN ALEGRE
5 SETAREH LAW GROUP Deputy Clerk
9665 Wilshire Blvd., Suite 430
6 Beverly Hills, California 90212
Telephone (310) 888-7771
7 Facsimile (310) 888-0109
8 Attorneys for Plaintiff
DONNA TREVETHAN
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10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 FOR THE COUNTY OF SAN FRANCISCO
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UNLIMITED JURISDICTION
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DONNA TREVETHAN, on behalf of herself, Case No. :CGC-19-579858
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all others similarly situated,
15 Hon. Ethan P. Schulman
Plaintiff,
16 CLASS ACTION
vs.
17 DECLARATION OF EVELIN REYES
BIG ORANGE PRODUCTIONS, INC., a REGARDING DISBURSEMENT
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RHODE ISLAND corporation; TARGET
19 CORPORATION, a MINNESOTA corporation;
and DOES 1 through 50, inclusive,
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Defendants..
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DECLARATION OF EVELIN REYES REGARDING DISBURSEMENT
1 DECLARATION OF EVELIN REYES
2 I, Evelin Reyes, hereby declare:
3 1. I am employed as a Case Manager by Simpluris, Inc. (“Simpluris”), the claims
4 administrator in the above-entitled action. Our Corporate Office address is 3194-C Airport Loop Drive,
5 Costa Mesa, CA 92626. My telephone number is (714) 640-5654. I am over twenty-one years of age
6 and authorized to make this declaration on behalf of Simpluris and myself.
7 2. Simpluris is a Class Action Settlement Administration company located in Costa Mesa,
8 California. It was founded by individuals who have each managed hundreds of settlements, along with
9 professionals in the areas of Software Development, Third-Party Claims Administration, Mail-House
10 Operations, and Call Center Support Management.
11 3. On November 5, 2021, Simpluris received a wire deposit from Defendant in the amount
12 of $700,000.00. In total, Simpluris received $700,000.00.
13 4. On January 4, 2022, Simpluris issued Settlement checks to the one thousand seventy-six
14 (1076) Participating Class Members. The checks were mailed via USPS.
15 5. The amount to be disbursed totaled:
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Amount deposited in disbursement account $ 700,000.00
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Class Counsel Fees $ 233,333.33
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Class Counsel Costs $ 12,557.51
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Named Plaintiff Service Awards $ 5,000.00
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Administration Costs $ 11,620.00
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Participating Class Member Payments $ 437,489.16
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Account Balance = $ 0.00
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6. The check-cashing period expires on July 3, 2022, which is 180 days from the issuance
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date of January 4, 2022.
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7. As of this date, there are a total of two hundred thirty (230) un-cashed checks, totaling
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$54,026.04.
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DECLARATION OF EVELIN REYES REGARDING DISBURSEMENT
1 8. Pursuant to the Stipulation of Class Action Settlement and Release, the funds
2 represented by uncashed checks which remain outstanding 180 calendar days after the mailing of the
3 settlement checks by the Claims Administrator shall be voided and forwarded to the Legal Aid at
4 Work.
5 9. Simpluris will issue a payment to Legal Aid at Work for the funds which remain
6 uncashed after the July 3, 2022 check cashing deadline.
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8 I declare under penalty of perjury under the laws of the State of California that the foregoing is
9 true and correct and that this declaration was executed on this 3rd day of June, 2022, in Costa Mesa,
10 California.
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12 ________________________________
13 Evelin Reyes
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DECLARATION OF EVELIN REYES REGARDING DISBURSEMENT
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PROOFOF SERVICE
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I am a citizenofthe United Statesandam employed in the County ofLos Angeles, State
3 of California. I am over the age of 18 and not a party to the within action. My business address
is 9665 Wilshire Blvd, Suite 430 Beverly Hills, CA 90212.
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On June 3, 2022, 1 served the foregoing documents described as:
6 DECLARATIONOF EVELENREYESREGARDINGDISBURSEMENT
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in this actionby transmitting a true copythereofaddressedas follows:
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Brandon R. McKelvey Emily F. Fox
9 brandon medinamckelve . corn efox wilsontumerkosmo. com
Timothy B. Nelson DouglasR. Clifford
10 timi it edinamckelve v -corn
111 dclifforditt'wilsontumerkosmo. com
Allison S. Hyatt WILSONTURNERKOSMOLLP
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allison medinamckelve .corn 402 WestBroadway, Suite 1600
12 SamanthaShapiro SanDiego, CA 92101
samantha medinamckelve . corn Counsel for Defendant TARGET
13 MEDINA MCKELVEY LLP CORPORATION
983 Reserve Drive
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Roseville, CA 95678
15 Counsel for Defendant BIG ORANGE
PRODUCTIONS, F\C.
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[X] ONLY BY ELECTRONIC TRANSMISSION
18 Basedon a court order or an agreementofthe parties to accept serviceby electronic
transmission, I electronically served the document(s) to the persons at the electronic service
19 addresses listed above.
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[X] STATE I declare under penalty of perjury under the laws of the State of California that
21 the above is true and correct.
22 Executed on June 3, 2022 at Beverly Hills, California.
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25 endy Sarabia
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PROOFOF SERVICE
Preview
1 Shaun Setareh (SBN 204514) shaun@setarehlaw.com 2 ELECTRONICALLY Thomas Segal (SBN 222791) thomas@setarehlaw.com F I L E D 3 Jose Maria D. Paitno, Jr. (SBN 270194) Superior Court of California, County of San Francisco jose@setarehlaw.com 4 Tyson Gibb (SBN 339154) 06/03/2022 tyson@setarehlaw.com Clerk of the Court BY: EDNALEEN ALEGRE 5 SETAREH LAW GROUP Deputy Clerk 9665 Wilshire Blvd., Suite 430 6 Beverly Hills, California 90212 Telephone (310) 888-7771 7 Facsimile (310) 888-0109 8 Attorneys for Plaintiff DONNA TREVETHAN 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 FOR THE COUNTY OF SAN FRANCISCO 12 UNLIMITED JURISDICTION 13 DONNA TREVETHAN, on behalf of herself, Case No. :CGC-19-579858 14 all others similarly situated, 15 Hon. Ethan P. Schulman Plaintiff, 16 CLASS ACTION vs. 17 DECLARATION OF EVELIN REYES BIG ORANGE PRODUCTIONS, INC., a REGARDING DISBURSEMENT 18 RHODE ISLAND corporation; TARGET 19 CORPORATION, a MINNESOTA corporation; and DOES 1 through 50, inclusive, 20 Defendants.. 21 22 23 24 25 26 27 28 DECLARATION OF EVELIN REYES REGARDING DISBURSEMENT 1 DECLARATION OF EVELIN REYES 2 I, Evelin Reyes, hereby declare: 3 1. I am employed as a Case Manager by Simpluris, Inc. (“Simpluris”), the claims 4 administrator in the above-entitled action. Our Corporate Office address is 3194-C Airport Loop Drive, 5 Costa Mesa, CA 92626. My telephone number is (714) 640-5654. I am over twenty-one years of age 6 and authorized to make this declaration on behalf of Simpluris and myself. 7 2. Simpluris is a Class Action Settlement Administration company located in Costa Mesa, 8 California. It was founded by individuals who have each managed hundreds of settlements, along with 9 professionals in the areas of Software Development, Third-Party Claims Administration, Mail-House 10 Operations, and Call Center Support Management. 11 3. On November 5, 2021, Simpluris received a wire deposit from Defendant in the amount 12 of $700,000.00. In total, Simpluris received $700,000.00. 13 4. On January 4, 2022, Simpluris issued Settlement checks to the one thousand seventy-six 14 (1076) Participating Class Members. The checks were mailed via USPS. 15 5. The amount to be disbursed totaled: 16 Amount deposited in disbursement account $ 700,000.00 17 Class Counsel Fees $ 233,333.33 18 Class Counsel Costs $ 12,557.51 19 Named Plaintiff Service Awards $ 5,000.00 20 Administration Costs $ 11,620.00 21 Participating Class Member Payments $ 437,489.16 22 Account Balance = $ 0.00 23 24 6. The check-cashing period expires on July 3, 2022, which is 180 days from the issuance 25 date of January 4, 2022. 26 7. As of this date, there are a total of two hundred thirty (230) un-cashed checks, totaling 27 $54,026.04. 28 1 DECLARATION OF EVELIN REYES REGARDING DISBURSEMENT 1 8. Pursuant to the Stipulation of Class Action Settlement and Release, the funds 2 represented by uncashed checks which remain outstanding 180 calendar days after the mailing of the 3 settlement checks by the Claims Administrator shall be voided and forwarded to the Legal Aid at 4 Work. 5 9. Simpluris will issue a payment to Legal Aid at Work for the funds which remain 6 uncashed after the July 3, 2022 check cashing deadline. 7 8 I declare under penalty of perjury under the laws of the State of California that the foregoing is 9 true and correct and that this declaration was executed on this 3rd day of June, 2022, in Costa Mesa, 10 California. 11 12 ________________________________ 13 Evelin Reyes 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 DECLARATION OF EVELIN REYES REGARDING DISBURSEMENT 1 PROOFOF SERVICE 2 I am a citizenofthe United Statesandam employed in the County ofLos Angeles, State 3 of California. I am over the age of 18 and not a party to the within action. My business address is 9665 Wilshire Blvd, Suite 430 Beverly Hills, CA 90212. 4 5 On June 3, 2022, 1 served the foregoing documents described as: 6 DECLARATIONOF EVELENREYESREGARDINGDISBURSEMENT 7 in this actionby transmitting a true copythereofaddressedas follows: 8 Brandon R. McKelvey Emily F. Fox 9 brandon medinamckelve . corn efox wilsontumerkosmo. com Timothy B. Nelson DouglasR. Clifford 10 timi it edinamckelve v -corn 111 dclifforditt'wilsontumerkosmo. com Allison S. Hyatt WILSONTURNERKOSMOLLP 11 allison medinamckelve .corn 402 WestBroadway, Suite 1600 12 SamanthaShapiro SanDiego, CA 92101 samantha medinamckelve . corn Counsel for Defendant TARGET 13 MEDINA MCKELVEY LLP CORPORATION 983 Reserve Drive 14 Roseville, CA 95678 15 Counsel for Defendant BIG ORANGE PRODUCTIONS, F\C. 16 17 [X] ONLY BY ELECTRONIC TRANSMISSION 18 Basedon a court order or an agreementofthe parties to accept serviceby electronic transmission, I electronically served the document(s) to the persons at the electronic service 19 addresses listed above. 20 [X] STATE I declare under penalty of perjury under the laws of the State of California that 21 the above is true and correct. 22 Executed on June 3, 2022 at Beverly Hills, California. 23 24 25 endy Sarabia 26 27 28 1 PROOFOF SERVICE