On September 25, 2020 a
Party Notice
was filed
involving a dispute between
Villegas, Maria,
and
Does 1-50,
Myojo Usa, Inc.,
Square One Staffing,
for Employment - Complex
in the District Court of San Bernardino County.
Preview
V onlamAL
LAW OFFICE 0F SCOTT ERNEST WHEELER
Scott ErnestWheeler (SBN 187998)
Wheeler (SBN 342226)
Justin A.
250 West First Street, Suite 216 F l L
SUPERIOR COURT OF CALIFORNIA
ED
Claremont, California 9 1 71 1 COUNTY OF SAN BERNARDINO
WW
Telephone: (909) 621-4988 SAN BERmpnwn mSTRICT
Facsimile: (909) 62 1 -4622
Email: sew@scottwheelerlawoffice.com MAY 1 B 2023
\DOONQUI-PUJNr—t
jaw@scottwheelerlawoffice.com
BY
Attorneysfor Plaintifland the Putative Class FAEL HERNANDEL, DEPUTY
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
SAN BERNARDINO DISTRICT
MARIA VILLEGAS, individually, and CASE NO, CIVD32020848
0n behalf of all others similarly situated,
[Hon. David Cohn, Dept. 8-26]
Plaintiff,
NNNNNNNHHHHp—AHr—Ab—tr—KH
V.
SUPPLEMENTAL DECLARATION OF
MYOJO USA, INC., a corporation; KEVIN LEE REGARDING SETTLEMENT
SQUARE ONE STAFFING; and DOES 1 NOTICE ADMINISTRATION
through 50, inclusive,
gSONU‘I-hUJNt—‘OKOOOQQUIAUJNHO
Defendants-
D t : M 15, 2023
Tianfe: 9:83] am.
Dept: S-26
Action Filed: September 25, 2020
Trial Date: None Set
SUPPLEMENTAL DECLARATION 0F KEVIN LEE REGARDING SETTLEMENT NOTICE ADMINISTRATION
SUPPLEMENTAL DECLARATION 0F KEVIN LEE
I, Kevin Lee, declare as follows:
1. I am a Case Manager at Phoenix Settlement Administrators (“Phoenix”), the Coun-
appointed Class Action Settlement Administrator for Maria Villegas v. Myojo USA, Ina, Square
Stafiing, et al. (the “Action”). I have personal knowledge of the facts stated herein and, if called
upon to testify, I could and would testify competently to such facts.
2. On March 8, 2023, Phoenix mailed the Notice Via U.S. first class mail, in English,
Spanish and Mandarin, to all six hundred twenty-two (622) Class Members on the Class List.
3. As of the date of this declaration, fony-five (45) Notices have been returned to
10 Phoenix. None were returned with a forwarding address. For the forty-five (45) Notices returned
11 from the Post Office without a forwarding address, Phoenix attempted to locate a current mailing
12 address using TransUnion TLOxp, one of the most comprehensive address databases available for
13 skip tracing. Ofthe forty-five (45) Notices that were skip traced, twenty—five (25) updated addresses
14 were obtained and the Notice was promptly re-mailed to those Class Members Via first class mail.
15 4. As of the date of this declaration, twenty (20) Notices remain undeliverable,
16 specifically since an updated address could not be obtained via skip trace.
17 5. As of the date of this declaration, Phoenix has received zero 10) Requests for
18 Exclusion from Class Members. The deadline to request exclusion from the Class Settlement was
19 April 22, 2023.
20 6. As of the date ofthis declaration, Phoenix has received zero (0) Notices of Obiection
21 from Class Members. The deadline for objecting to the Class Settlement was April 22, 2023.
22 7. As of the date of this declaration, Phoenix has received zero (0) Workweek disputes
23 from Class Members. The deadline for submitting a dispute was April 22, 2023.
24 8. There are six hundred twenty-two (622) Class Members who have not submitted
25 timely and valid Requests for Exclusion and are therefore deemed Settlement Class Members,
26 representing 100% of the Class. Settlement Class Members have worked a collective total of nine
27
28
-1-
SUPPLEMENTAL DECLARATION 0F KEVIN LEE REGARDING SETTLEMENT NOTICE ADMINISTRATION
Document Filed Date
May 10, 2023
Case Filing Date
September 25, 2020
Category
Employment - Complex
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Preview
V onlamAL LAW OFFICE 0F SCOTT ERNEST WHEELER Scott ErnestWheeler (SBN 187998) Wheeler (SBN 342226) Justin A. 250 West First Street, Suite 216 F l L SUPERIOR COURT OF CALIFORNIA ED Claremont, California 9 1 71 1 COUNTY OF SAN BERNARDINO WW Telephone: (909) 621-4988 SAN BERmpnwn mSTRICT Facsimile: (909) 62 1 -4622 Email: sew@scottwheelerlawoffice.com MAY 1 B 2023 \DOONQUI-PUJNr—t jaw@scottwheelerlawoffice.com BY Attorneysfor Plaintifland the Putative Class FAEL HERNANDEL, DEPUTY SUPERIOR COURT OF THE STATE 0F CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT MARIA VILLEGAS, individually, and CASE NO, CIVD32020848 0n behalf of all others similarly situated, [Hon. David Cohn, Dept. 8-26] Plaintiff, NNNNNNNHHHHp—AHr—Ab—tr—KH V. SUPPLEMENTAL DECLARATION OF MYOJO USA, INC., a corporation; KEVIN LEE REGARDING SETTLEMENT SQUARE ONE STAFFING; and DOES 1 NOTICE ADMINISTRATION through 50, inclusive, gSONU‘I-hUJNt—‘OKOOOQQUIAUJNHO Defendants- D t : M 15, 2023 Tianfe: 9:83] am. Dept: S-26 Action Filed: September 25, 2020 Trial Date: None Set SUPPLEMENTAL DECLARATION 0F KEVIN LEE REGARDING SETTLEMENT NOTICE ADMINISTRATION SUPPLEMENTAL DECLARATION 0F KEVIN LEE I, Kevin Lee, declare as follows: 1. I am a Case Manager at Phoenix Settlement Administrators (“Phoenix”), the Coun- appointed Class Action Settlement Administrator for Maria Villegas v. Myojo USA, Ina, Square Stafiing, et al. (the “Action”). I have personal knowledge of the facts stated herein and, if called upon to testify, I could and would testify competently to such facts. 2. On March 8, 2023, Phoenix mailed the Notice Via U.S. first class mail, in English, Spanish and Mandarin, to all six hundred twenty-two (622) Class Members on the Class List. 3. As of the date of this declaration, fony-five (45) Notices have been returned to 10 Phoenix. None were returned with a forwarding address. For the forty-five (45) Notices returned 11 from the Post Office without a forwarding address, Phoenix attempted to locate a current mailing 12 address using TransUnion TLOxp, one of the most comprehensive address databases available for 13 skip tracing. Ofthe forty-five (45) Notices that were skip traced, twenty—five (25) updated addresses 14 were obtained and the Notice was promptly re-mailed to those Class Members Via first class mail. 15 4. As of the date of this declaration, twenty (20) Notices remain undeliverable, 16 specifically since an updated address could not be obtained via skip trace. 17 5. As of the date of this declaration, Phoenix has received zero 10) Requests for 18 Exclusion from Class Members. The deadline to request exclusion from the Class Settlement was 19 April 22, 2023. 20 6. As of the date ofthis declaration, Phoenix has received zero (0) Notices of Obiection 21 from Class Members. The deadline for objecting to the Class Settlement was April 22, 2023. 22 7. As of the date of this declaration, Phoenix has received zero (0) Workweek disputes 23 from Class Members. The deadline for submitting a dispute was April 22, 2023. 24 8. There are six hundred twenty-two (622) Class Members who have not submitted 25 timely and valid Requests for Exclusion and are therefore deemed Settlement Class Members, 26 representing 100% of the Class. Settlement Class Members have worked a collective total of nine 27 28 -1- SUPPLEMENTAL DECLARATION 0F KEVIN LEE REGARDING SETTLEMENT NOTICE ADMINISTRATION