On June 10, 2019 a
Motion-Secondary
was filed
involving a dispute between
Alcantar, Alejandro,
and
Does 1 Through 100,
Nitto Tire U.S.A. Inc.,
Toyo Tire Holdings Of Americas Inc. A California Corporation,
Toyo Tire U.S.A. Corp.,
for Employment-Other
in the District Court of San Bernardino County.
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V
Edwin Aiwazian (SBN 232943)
Arby Aiwazian (SBN 269827) F 5 E.
comm 0r CALJFORMA
ED
sgfigglqm
Joanna Ghosh (SBN 272479) -3:
{pf
0F SAN BEHNARDINO
a_‘y
A bazwARDINQ DISTRtCT
LAWYERS for JUSTICE, PC
410 West Arden Avenue, Suite 203
Glendale, California 9 1203 MAR, i: 3 2021.
Tel: (818) 265-1020 / Fax: (818) 265-1021
KOOONONLJ‘IbbJNv—I
Attorneys for Plaintiff _~, ‘H,
«HADELS: Rife, WWW
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
ALEJANDRO ALCANTAR, individually, and Case No.2 CIVDS 1917327
0n behalf of other members of the general
public similarly situated; Honorable David S. Cohn
PC
Department $26
W1!
203
Suite
Plaintiff,
91203
JUSTICE,
vs.
Avenue,
California
DECLARATION OF ALEJANDRO
for TOYO TIRE HOLDINGS OF AMERICAS ALCANTAR IN SUPPORT OF
Arden
INC., a California corporation; and DOES 1 PLAINTIFF’S MOTION FOR
Glendale,
through 100, inclusive, PRELIMINARY APPROVAL OF CLASS
LAWYERS
West
ACTION SETTLEMENT
Defendants.
410
[Notice of Motion and Motion for
Preliminary Approval 0f Class Action
Settlement; Declaration of Proposed Class
NNNNNNNNNHMHHp—awp—Ar—Au—AH
Counsel (Edwin Aiwazian); and [Proposed]
OOQQUIhUJNr-‘OKOOOQONU‘IAUJNh-‘O
Order filed concurrently herewith.]
Date: March 25, 2021
Time: 10:00 am.
Department: 826
Complaint Filed: June 19, 2019
Jury Trial: None Set
DECLARATION 0F ALEJANDRO ALCANTAR
V \a
DECLARATION OF ALEJANDRO ALCANTAR
I, Alejandro Alcantar, hereby declare as follows:
1. Iam over 18 years of age and a resident of California. I am the named plaintiff in
the above—captioned case. Ihave personal knowledge of the facts and statements set forth in this
\OOOQONLJI-hLQNn—I
declaration, and if called upon to testify, I could and would competently testify thereto.
2. Iwas employed by Defendant Toyo Tire Holdings of Americas Inc. (“Toyo Tire”)
in an hourly-paid, non-exempt position from approximately May 2014 to April 2017. I decided
to seek legal advice about my work experiences with Toyo Tire and about pursuing my
grievances. I contacted Lawyers for Justice, PC and spoke with attorneys there. I wanted to d0
whatever I could to make sure Toyo Tire paid me and other employees what was owed to us for
all hours worked and non-compliant meal and rest breaks. After speaking with the attorneys, I
PC
203
investigated complex wage-and-hour lawsuits on rny own and did some research into the leading
Suite
91203
JUSTICE,
class action and employment law firms in California for approximately 7 hours. Thereafter, I
Avenue,
California
consulted with the attorneys at Lawyers for Justice, PC for 6 hours to discuss my situation,
Arden
complex wage—and—hour class actions and representative actions under the Private Attorneys
Glendale,
LAWYERSfor
West
General Act (“PAGA”) in general, and what it meant to be a named plaintiff, class
410
representative, and eventually, a PAGA representative.
NNNNNNNNNn—ib‘h—‘Hpr—At—AHp—a
3. I have spent over 15 hours meeting with my attorneys and fulfilling my
responsibilities as a class representative in this case, which included gathering documents
my
WQOU‘I-bUJN—‘OKOOOQQUIAWNHO
employment with Toyo Tire, reviewing documents with attorneys and
concerning my
answering their questions, answering questions and providing guidance regarding the
work
and
performed by non-exempt employees, and helping develop a strategy as t0 what documents
information to obtain from Toyo Tire. I frequently checked in with my attorneys and their staff
and any additional information that I had
t0 make sure that they had my most current information
obtained.
4. Throughout the case, I was available to answer any questions my attorneys had,
and available to speak and meet with them whenever they needed me. I responded to my
attorneys as quickly as possible and gave them as much information and identified as many
l
DECLARATION OF ALEJANDRO ALCANTAR
Document Filed Date
March 19, 2021
Case Filing Date
June 10, 2019
Category
Employment-Other
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V Edwin Aiwazian (SBN 232943) Arby Aiwazian (SBN 269827) F 5 E. comm 0r CALJFORMA ED sgfigglqm Joanna Ghosh (SBN 272479) -3: {pf 0F SAN BEHNARDINO a_‘y A bazwARDINQ DISTRtCT LAWYERS for JUSTICE, PC 410 West Arden Avenue, Suite 203 Glendale, California 9 1203 MAR, i: 3 2021. Tel: (818) 265-1020 / Fax: (818) 265-1021 KOOONONLJ‘IbbJNv—I Attorneys for Plaintiff _~, ‘H, «HADELS: Rife, WWW SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO ALEJANDRO ALCANTAR, individually, and Case No.2 CIVDS 1917327 0n behalf of other members of the general public similarly situated; Honorable David S. Cohn PC Department $26 W1! 203 Suite Plaintiff, 91203 JUSTICE, vs. Avenue, California DECLARATION OF ALEJANDRO for TOYO TIRE HOLDINGS OF AMERICAS ALCANTAR IN SUPPORT OF Arden INC., a California corporation; and DOES 1 PLAINTIFF’S MOTION FOR Glendale, through 100, inclusive, PRELIMINARY APPROVAL OF CLASS LAWYERS West ACTION SETTLEMENT Defendants. 410 [Notice of Motion and Motion for Preliminary Approval 0f Class Action Settlement; Declaration of Proposed Class NNNNNNNNNHMHHp—awp—Ar—Au—AH Counsel (Edwin Aiwazian); and [Proposed] OOQQUIhUJNr-‘OKOOOQONU‘IAUJNh-‘O Order filed concurrently herewith.] Date: March 25, 2021 Time: 10:00 am. Department: 826 Complaint Filed: June 19, 2019 Jury Trial: None Set DECLARATION 0F ALEJANDRO ALCANTAR V \a DECLARATION OF ALEJANDRO ALCANTAR I, Alejandro Alcantar, hereby declare as follows: 1. Iam over 18 years of age and a resident of California. I am the named plaintiff in the above—captioned case. Ihave personal knowledge of the facts and statements set forth in this \OOOQONLJI-hLQNn—I declaration, and if called upon to testify, I could and would competently testify thereto. 2. Iwas employed by Defendant Toyo Tire Holdings of Americas Inc. (“Toyo Tire”) in an hourly-paid, non-exempt position from approximately May 2014 to April 2017. I decided to seek legal advice about my work experiences with Toyo Tire and about pursuing my grievances. I contacted Lawyers for Justice, PC and spoke with attorneys there. I wanted to d0 whatever I could to make sure Toyo Tire paid me and other employees what was owed to us for all hours worked and non-compliant meal and rest breaks. After speaking with the attorneys, I PC 203 investigated complex wage-and-hour lawsuits on rny own and did some research into the leading Suite 91203 JUSTICE, class action and employment law firms in California for approximately 7 hours. Thereafter, I Avenue, California consulted with the attorneys at Lawyers for Justice, PC for 6 hours to discuss my situation, Arden complex wage—and—hour class actions and representative actions under the Private Attorneys Glendale, LAWYERSfor West General Act (“PAGA”) in general, and what it meant to be a named plaintiff, class 410 representative, and eventually, a PAGA representative. NNNNNNNNNn—ib‘h—‘Hpr—At—AHp—a 3. I have spent over 15 hours meeting with my attorneys and fulfilling my responsibilities as a class representative in this case, which included gathering documents my WQOU‘I-bUJN—‘OKOOOQQUIAWNHO employment with Toyo Tire, reviewing documents with attorneys and concerning my answering their questions, answering questions and providing guidance regarding the work and performed by non-exempt employees, and helping develop a strategy as t0 what documents information to obtain from Toyo Tire. I frequently checked in with my attorneys and their staff and any additional information that I had t0 make sure that they had my most current information obtained. 4. Throughout the case, I was available to answer any questions my attorneys had, and available to speak and meet with them whenever they needed me. I responded to my attorneys as quickly as possible and gave them as much information and identified as many l DECLARATION OF ALEJANDRO ALCANTAR