On May 30, 2018 a
Motion-Secondary
was filed
involving a dispute between
Abdullah Uzair,
Angel Chavez,
Nicholas Joel Luskin,
Salvador De La O,
and
Google, Llc,
for civil
in the District Court of Santa Clara County.
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Laura L. Ho (SBN 173179)
lho@gbdhlegal.com
James Kan (SBN 240749)
jkan@gbdhlegal.com
Katharine L. Fisher (SBN 305413)
kfisher@gbdhlegal.com
Mengfei Sun (SBN 328829)
msun@gbdhlegal.com
GOLDSTEIN, BORGEN, DARDARIAN & HO
155 Grand Avenue, Suite 900
Oakland, CA 94612
Tel: (510) 763-9800
Fax: (510) 835-1417
Julian Hammond (SBN 268489)
jhammond@hammondlawpc.com
Ari Cherniak (SBN 290071)
acherniak@hammondlawpc.com
Polina Brandler (SBN 269086)
pbrandler@hammondlawpc.com
HAMMONDLAW, PC
1201 Pacific Avenue, Suite 600
Tacoma, WA 98402
Tel: (310) 601-6766
Fax: (310) 295-2385
Attorneys for Plaintiffs and the CertifiedClass
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA CLARA
ANGEL CHAVEZ, NICHOLAS JOEL LUSKIN, Case No. 18CV328915
and SALVADOR DE LA O, individually and on
behalf of all others similarly situated DECLARATION OF SCOTT GRIMESIN
SUPPORT OF PLAINTIFFS’ MOTION TO
Plaintiffs, EXCLUDE DECLARATION OF YINGYI
s.
Date: September 28, 2023
GOOGLE, LLC.a California Limited Liability Time: 1:30 p.m.
Company, Dept: 1
Before: Hon. Sunil R. Kulkarni
Defendant
TrialDate: None Set
REDACTED - PUBLIC VERSION
ECL OF COTT RIMES IN UPP OF LS TO XCLUDE ECL OF INGYI ASE 18CV328915
876421.5
I, Scott Grimes, declare as follows:
I am a Senior Paralegal with the law firm Goldstein, Borgen, Dardarian & Ho (GBDH)
in Oakland, California, where I have worked for over 30 years. I hold a Masters of Science degree in
Statistics from California State University East Bay. I have over 25 years of experience with using
Excel as part of my regular job duties at GBDH. I have personal knowledge of the facts set forth in
this declaration and could and would testify competently to them.
I am providing this declaration in support of Plaintiffs’ Motion to Exclude the
Declaration of Yingyi Yang.
Upon receipt of Google’s July 27, 2023 Motion to Decertify and supporting Yang
declaration, I was asked to recreate the calculations made by Ms. Yang using data from PROD_025.
I determined that the data in PROD_025 was insufficient to recreate Ms. Yang’
calculations because, among other things,
Upon receipt of PROD, I tried to recreate the calculations made by Ms. Yang
based on the methodology provided by Google in its August 9, 2023 email. I was unable to recreate
her calculations
Upon receipt of PROD_027, I once again tried to replicate Ms. Yang’s calculations.
was still unable to replicate Ms. Yang’s results and based on my calculations, Ms. Yang’s analysis
overstates their results
I declare under penalty of perjury under the laws of the State of California and the United
States that the foregoing is true and correct. Executed August 31, 2023, in Oakland, CA.
Scott Grimes
ECL OF COTT RIMES IN UPP OF TO XCLUDE ECL OF INGYI ASE 18CV328915
876421.5
Document Filed Date
August 31, 2023
Case Filing Date
May 30, 2018
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Laura L. Ho (SBN 173179) lho@gbdhlegal.com James Kan (SBN 240749) jkan@gbdhlegal.com Katharine L. Fisher (SBN 305413) kfisher@gbdhlegal.com Mengfei Sun (SBN 328829) msun@gbdhlegal.com GOLDSTEIN, BORGEN, DARDARIAN & HO 155 Grand Avenue, Suite 900 Oakland, CA 94612 Tel: (510) 763-9800 Fax: (510) 835-1417 Julian Hammond (SBN 268489) jhammond@hammondlawpc.com Ari Cherniak (SBN 290071) acherniak@hammondlawpc.com Polina Brandler (SBN 269086) pbrandler@hammondlawpc.com HAMMONDLAW, PC 1201 Pacific Avenue, Suite 600 Tacoma, WA 98402 Tel: (310) 601-6766 Fax: (310) 295-2385 Attorneys for Plaintiffs and the CertifiedClass SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA ANGEL CHAVEZ, NICHOLAS JOEL LUSKIN, Case No. 18CV328915 and SALVADOR DE LA O, individually and on behalf of all others similarly situated DECLARATION OF SCOTT GRIMESIN SUPPORT OF PLAINTIFFS’ MOTION TO Plaintiffs, EXCLUDE DECLARATION OF YINGYI s. Date: September 28, 2023 GOOGLE, LLC.a California Limited Liability Time: 1:30 p.m. Company, Dept: 1 Before: Hon. Sunil R. Kulkarni Defendant TrialDate: None Set REDACTED - PUBLIC VERSION ECL OF COTT RIMES IN UPP OF LS TO XCLUDE ECL OF INGYI ASE 18CV328915 876421.5 I, Scott Grimes, declare as follows: I am a Senior Paralegal with the law firm Goldstein, Borgen, Dardarian & Ho (GBDH) in Oakland, California, where I have worked for over 30 years. I hold a Masters of Science degree in Statistics from California State University East Bay. I have over 25 years of experience with using Excel as part of my regular job duties at GBDH. I have personal knowledge of the facts set forth in this declaration and could and would testify competently to them. I am providing this declaration in support of Plaintiffs’ Motion to Exclude the Declaration of Yingyi Yang. Upon receipt of Google’s July 27, 2023 Motion to Decertify and supporting Yang declaration, I was asked to recreate the calculations made by Ms. Yang using data from PROD_025. I determined that the data in PROD_025 was insufficient to recreate Ms. Yang’ calculations because, among other things, Upon receipt of PROD, I tried to recreate the calculations made by Ms. Yang based on the methodology provided by Google in its August 9, 2023 email. I was unable to recreate her calculations Upon receipt of PROD_027, I once again tried to replicate Ms. Yang’s calculations. was still unable to replicate Ms. Yang’s results and based on my calculations, Ms. Yang’s analysis overstates their results I declare under penalty of perjury under the laws of the State of California and the United States that the foregoing is true and correct. Executed August 31, 2023, in Oakland, CA. Scott Grimes ECL OF COTT RIMES IN UPP OF TO XCLUDE ECL OF INGYI ASE 18CV328915 876421.5