Preview
1 Shaun Setareh (SBN 204514)
shaun@setarehlaw.com
2 Thomas Segal (SBN 222791) ELECTRONICALLY
thomas@setarehlaw.com
3 Jose Maria D. Paitno, Jr. (SBN 270194) F I L E D
Superior Court of California,
jose@setarehlaw.com County of San Francisco
4 Tyson Gibb (SBN 339154)
tyson@setarehlaw.com 06/03/2022
Clerk of the Court
5 SETAREH LAW GROUP BY: EDNALEEN ALEGRE
9665 Wilshire Blvd., Suite 430 Deputy Clerk
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
12 UNLIMITED JURISDICTION
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14 DONNA TREVETHAN, on behalf of herself, Case No. CGC-19-579858
all others similarly situated,
15 DECLARATION OF THOMAS SEGAL
Plaintiff, REGARDING SETTLEMENT
16 ADMINISTRATOR DISBURSEMENT
vs. REPORT
17
BIG ORANGE PRODUCTIONS, INC., a
18 Rhode Island corporation; TARGET
CORPORATION, a Minnesota corporation;
19 and DOES 1 through 50, inclusive,
20 Defendants.
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DECLARATION OF THOMAS SEGAL RE: SETTLEMENT ADMINISTRATOR DISBURSEMENT REPORT
1 DECLARATION OF THOMAS SEGAL
2 I, Thomas Segal, declare as follows:
3 1. I am an attorney admitted and licensed to practice in the State of California and
4 before this Court. The matters stated in this declaration are known to me based upon my own
5 personal knowledge, except as otherwise stated. I am a Senior Associate at the law firm of Setareh
6 Law Group, counsel of record for Plaintiff Donna Trevethan in this matter.
7 2. Following this Court granting final approval of the Parties’ Settlement, this office’s
8 calendaring clerk was instructed to set a Compliance Hearing in this matter on the firm’s internal
9 calendar for June 6, 2022 at 9:30 a.m., with a task to submit a declaration from the settlement
10 administrator as to the status of the settlement distribution ahead of the Compliance Hearing.
11 3. The deadline for submitting the declaration was set for June 2, 2022. In retrospect,
12 that task should have been set further back in time to allow for more of a buffer.
13 4. On June 2, 2022 at 10:53 a.m. I sent an email to our contact at the settlement
14 administrator Simpluris requesting that they provide a declaration that same day regarding the status
15 of disbursement in this case.
16 5. The following day, on June 3, 2022 at 9:44 a.m., I received communication from
17 another associate of Simpluris informing me that she would be the new daily contact for the
18 remainder of this case, and that Simpluris would provide a declaration by no later than Monday,
19 June 6, 2022.
20 6. I responded minutes later informing Simpluris that Monday would be too late
21 because the Compliance Hearing was set for that date. I further requested that they send the
22 declaration same day, on Friday June 3, 2022, so that we could promptly file it with this Court
23 ahead of the Compliance Hearing.
24 7. If this firm receives the declaration ahead of the Compliance Hearing it will be
25 immediately filed.
26 8. In any event, I apologize to the Court for the late filing. No disrespect to the Court
27 was intended by the late filing. Upon receipt of the disbursement report, we will promptly file it for
28 the Court’s review.
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DECLARATION OF THOMAS SEGAL RE: SETTLEMENT ADMINISTRATOR DISBURSEMENT REPORT
1 I declareunderthepenalty ofperjury under the laws ofthe StateofCaliforniathat the
2 foregoingis tme and correct.
3 Executedon June3, 2022, at Beverly Hills, California.
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6 THOM SEGAL
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DECLARATIONOF THOMAS SEGALRE: SETTLEMENTADMINISTRATORDISBURSEMENTREPORT
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PROOF OF SERVICE
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I am a citizenofthe United States andam employed in the County ofLos Angeles, State
3 ofCalifornia. I am over the ageof 18 andnot a party to the withinaction. My businessaddress
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 THOMAS SEGALREGARDINGSETTLEMENT
ADMENISTRATOR DISBURSEMENT REPORT
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in this actionby transmitting a b-uecopy thereofaddressedas follows:
9 Brandon R. McKelvey Emily F. Fox
brandon medinamckelve . corn efox wilsontumerkosmo. com
10 Timothy B. Nelson DouglasR. Clifford
tim medinamckelve .corn dclifford wilsontumerkosmo. com
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Allison S. Hyatt WILSONTURNERKOSMOLLP
12 allison edinamckelve .corn 402 West Broadway, Suite 1600
Samantha Shapiro SanDiego, CA 92101
13 samantha medinamckelve . corn Counsel for DefendantTARGET
MEDINAMCKELVEYLLP CORPORATION
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983 Reserve Drive
15 Roseville, CA 95678
Counsel for DefendantBIG ORANGE
16 PRODUCTIONS, INC.
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[X] ONLY BY ELECTRONIC TRANSMISSION
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Basedon a court order or an agreement oftheparties to accept serviceby electronic
19 transmission, I electronically served the document(s) to the persons at the electronic service
addresses listed above.
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21 [X] STATE I declare under penalty of perjury under the laws of the State of California that
the above is tme and correct.
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Executedon June3, 2022 at Beverly Hills, California.
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en y ara la
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PROOFOF SERVICE
Preview
1 Shaun Setareh (SBN 204514) shaun@setarehlaw.com 2 Thomas Segal (SBN 222791) ELECTRONICALLY thomas@setarehlaw.com 3 Jose Maria D. Paitno, Jr. (SBN 270194) F I L E D Superior Court of California, jose@setarehlaw.com County of San Francisco 4 Tyson Gibb (SBN 339154) tyson@setarehlaw.com 06/03/2022 Clerk of the Court 5 SETAREH LAW GROUP BY: EDNALEEN ALEGRE 9665 Wilshire Blvd., Suite 430 Deputy Clerk 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 14 DONNA TREVETHAN, on behalf of herself, Case No. CGC-19-579858 all others similarly situated, 15 DECLARATION OF THOMAS SEGAL Plaintiff, REGARDING SETTLEMENT 16 ADMINISTRATOR DISBURSEMENT vs. REPORT 17 BIG ORANGE PRODUCTIONS, INC., a 18 Rhode Island corporation; TARGET CORPORATION, a Minnesota corporation; 19 and DOES 1 through 50, inclusive, 20 Defendants. 21 22 23 24 25 26 27 28 DECLARATION OF THOMAS SEGAL RE: SETTLEMENT ADMINISTRATOR DISBURSEMENT REPORT 1 DECLARATION OF THOMAS SEGAL 2 I, Thomas Segal, declare as follows: 3 1. I am an attorney admitted and licensed to practice in the State of California and 4 before this Court. The matters stated in this declaration are known to me based upon my own 5 personal knowledge, except as otherwise stated. I am a Senior Associate at the law firm of Setareh 6 Law Group, counsel of record for Plaintiff Donna Trevethan in this matter. 7 2. Following this Court granting final approval of the Parties’ Settlement, this office’s 8 calendaring clerk was instructed to set a Compliance Hearing in this matter on the firm’s internal 9 calendar for June 6, 2022 at 9:30 a.m., with a task to submit a declaration from the settlement 10 administrator as to the status of the settlement distribution ahead of the Compliance Hearing. 11 3. The deadline for submitting the declaration was set for June 2, 2022. In retrospect, 12 that task should have been set further back in time to allow for more of a buffer. 13 4. On June 2, 2022 at 10:53 a.m. I sent an email to our contact at the settlement 14 administrator Simpluris requesting that they provide a declaration that same day regarding the status 15 of disbursement in this case. 16 5. The following day, on June 3, 2022 at 9:44 a.m., I received communication from 17 another associate of Simpluris informing me that she would be the new daily contact for the 18 remainder of this case, and that Simpluris would provide a declaration by no later than Monday, 19 June 6, 2022. 20 6. I responded minutes later informing Simpluris that Monday would be too late 21 because the Compliance Hearing was set for that date. I further requested that they send the 22 declaration same day, on Friday June 3, 2022, so that we could promptly file it with this Court 23 ahead of the Compliance Hearing. 24 7. If this firm receives the declaration ahead of the Compliance Hearing it will be 25 immediately filed. 26 8. In any event, I apologize to the Court for the late filing. No disrespect to the Court 27 was intended by the late filing. Upon receipt of the disbursement report, we will promptly file it for 28 the Court’s review. 1 DECLARATION OF THOMAS SEGAL RE: SETTLEMENT ADMINISTRATOR DISBURSEMENT REPORT 1 I declareunderthepenalty ofperjury under the laws ofthe StateofCaliforniathat the 2 foregoingis tme and correct. 3 Executedon June3, 2022, at Beverly Hills, California. 4 5 6 THOM SEGAL 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATIONOF THOMAS SEGALRE: SETTLEMENTADMINISTRATORDISBURSEMENTREPORT 1 PROOF OF SERVICE 2 I am a citizenofthe United States andam employed in the County ofLos Angeles, State 3 ofCalifornia. I am over the ageof 18 andnot a party to the withinaction. My businessaddress 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 THOMAS SEGALREGARDINGSETTLEMENT ADMENISTRATOR DISBURSEMENT REPORT 7 8 in this actionby transmitting a b-uecopy thereofaddressedas follows: 9 Brandon R. McKelvey Emily F. Fox brandon medinamckelve . corn efox wilsontumerkosmo. com 10 Timothy B. Nelson DouglasR. Clifford tim medinamckelve .corn dclifford wilsontumerkosmo. com 11 Allison S. Hyatt WILSONTURNERKOSMOLLP 12 allison edinamckelve .corn 402 West Broadway, Suite 1600 Samantha Shapiro SanDiego, CA 92101 13 samantha medinamckelve . corn Counsel for DefendantTARGET MEDINAMCKELVEYLLP CORPORATION 14 983 Reserve Drive 15 Roseville, CA 95678 Counsel for DefendantBIG ORANGE 16 PRODUCTIONS, INC. 17 [X] ONLY BY ELECTRONIC TRANSMISSION 18 Basedon a court order or an agreement oftheparties to accept serviceby electronic 19 transmission, I electronically served the document(s) to the persons at the electronic service addresses listed above. 20 21 [X] STATE I declare under penalty of perjury under the laws of the State of California that the above is tme and correct. 22 Executedon June3, 2022 at Beverly Hills, California. 23 24 25 ,^ en y ara la 26 27 28 1 PROOFOF SERVICE