Document for Victoria Tice, etc., v. Trader Joe’s Company

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                                1 Larry W. Lee (State Bar No. 228175)
   Max W. Gavron (State Bar No. 291697)
 2 DIVERSITY LAW GROUP, P.C.
 3 515 S. Figueroa Street, Suite 1250
   Los Angeles, CA 90071
 4 (213) 488-6555
   (213) 488-6554 facsimile
 5 lwlee@diversitylaw.com
 6 mgavron@diversitylaw.com
 7 William L. Marder (State Bar No. 170131)
   Polaris Law Group
 8 501 San Benito Street, Suite 200
 9 Hollister, CA 95023
   (831) 531-4214
10 (831) 634-0333 facsimile
   bill@polarislawgroup.com
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12 Attorneys for Plaintiff and the Class
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                     SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                            FOR THE COUNTY OF SANTA BARBARA
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16 VICTORIA TICE, as an individual and on        Case No. 20CV00892
   behalf of all others similarly situated,
17                                               [Assigned to the Honorable Thomas P. Anderle,
                   Plaintiff,                    Department 3]
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19          vs.                                  DECLARATION OF VICTORIA TICE IN
                                                 SUPPORT OF
20                             , a California    FOR PRELIMINARY APPROVAL OF
   corporation; and DOES 1 through 50,           CLASS ACTION SETTLEMENT
21 inclusive,
22                                               Date: April 12, 2023
                   Defendants.                   Time: 10:00 A.M.
23                                               Dept.: 3
24                                               Complaint Filed:       February 14, 2020
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                                                 1

                                                            MOTION FOR PRELIMINARY APPROVAL
                                     OF CLASS ACTION SETTLEMENT
 1                               DECLARATION OF VICTORIA TICE
 2          I, Victoria Tice, declare as follows:
 3          1.      I am an individual over the age of 18 years old and am a resident of California. I
 4 am the named Plaintiff in this matter. I have personal knowledge of the facts set forth below and
 5 if called to testify I could and would do so competently.
 6          2.      I worked for Defendant                                                        2011
 7 until on or about January 27, 2020.
 8          3.      When I was terminated from employment, I was issued a paycard from which I
 9 was told I could access my final wages. I did not agree to being paid through this method, nor
10 did I authorize Defendant to pay my wages via paycard at any time during my employment.
11          4.      I was charged a fee to use the paycard and, as such, have been unable to access all
12 wages paid to me.
13          5.      I understand that this action was brought on behalf of all other employees in the
14 State of California, and that I am acting as a representative for the Settlement Class. As the Class
15 Representative, I understand that it is my responsibility to act in the best interests of the Class
16 and not my own. I agree that I will not put my own interests ahead of that of the Class.
17 Moreover, I am not aware of any conflicts that exist between my interests and the interests of the
18 Class that would impair or affect my ability to serve as representative for the Class.
19          6.      I have and continue to be willing to assist in the investigation of this matter,
20 including meeting, conferring, discussing the case with my attorneys, providing any necessary
21 information and documents, making myself available for trial or any further proceedings in this
22 matter as required to represent the interests of the Class. I also understand my duties and
23 responsibilities to the proposed Class and will carry out those duties as necessary.
24          7.      I have discussed the case with my attorneys on a number of occasions, provided
25 information and documents to my attorneys to help with the prosecution of the case, sat for
26 deposition, and reviewed documents in the case, including the Joint Stipulation of Class Action
27                                                           .
28          8.      I have discussed the terms of the Settlement Agreement with my attorneys, and
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                                                              MOTION FOR PRELIMINARY APPROVAL
                                       OF CLASS ACTION SETTLEMENT
1 based on the information provided, I believe the settlement to be fair, adequate, and reasonable
2 for myself and for the entire Class.
3         I declare under penalty of perjury under the laws of the State of California that the
4 foregoing is true and correct.
5         Executed on this 9th day of March 2023, at Carson City, Nevada.
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                                               _________________________________
7                                               Victoria Tice
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                                                           MOTION FOR PRELIMINARY APPROVAL
                                    OF CLASS ACTION SETTLEMENT