On October 15, 2019 a
Motion-Secondary
was filed
involving a dispute between
Brianna Flores,
Estremera, Tania,
Hansen, Dexter Norman,
and
Biscomerica Corp., A California Corporation,
Does 1-100,
for Employment - Complex
in the District Court of San Bernardino County.
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Edwin Aiwazian (SBN 232943) F i L E D
>
Arby Aiwazian (SBN 269827) :sLJPERIOR COURT .02: CALIFORNIA
Joanna Ghosh (SBN 272479) COUNTY 0F SAN BERNAHmNo
SAN BERNARDMO mmmm-
LAWYERS for JUSTICE, PC
410 West Arden Avenue, Suite 203
Glendale, California 91203
DEC 2 8 2022
Tel: (818) 265-1020 / Fax: (818) 265-1021
Attorneysfor Plaintiffs 337“” PAOLA INigUE «,‘Deputv
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10
BRIANNA FLORES, TANIA ESTREMERA, Case N0.: CIVDSI9308 14
individually, and 0n behalf 0f other members
11
PC
of the general public similarly situated; Honorable David S. Cohn
203
DEXTER NORMAN HANSEN, individually, Department $26
12
Suite
91203
and 0n behalf of the other aggrieved
JUSTICE, employees pursuant to the California Private CLASS ACTION
13
Attorneys General Act;
Avenue,
California
DECLARATION OF DEXTER
for
14
Plaintiffs, NORMAN HANSEN IN SUPPORT OF
Arden
PLAINTIFFS’ MOTION FOR FINAL
15
West
Glendale, vs. APPROVAL OF CLASS ACTION
LAWYERS
16 SETTLEMENT, ATTORNEYS FEES
410
BISCOMERICA CORR, a California
AND COSTS, AND ENHANCEMENT
corporation; and DOES through 100,
17
1
AWARDS
inclusive,
[Notice of Motion and Motion for
18 Final Approval 0f Class Action Settlement;
Defendants.
Declaration of Proposed Class Counsel (Ed-
19 win Aiwazian); Declarations of Proposed
Class Re resentatives (Tania Estremera,
20 Brianna and [Proposed] Order filed
lores);
concurrently herewith]
January 20, 2023
21 D :
Tiara: 10:00 a.m.
22 Department: $26
23 Complaint Filed: October 15, 2019
FAC Filed: July 28, 2021
24 Trial Date: None Set
25
26
27
28
DECLARATION OF DEXTER NORMAN HANSEN
\J V
DECLARATION 0F DEXTER NORMAN HANSEN
I, Dexter Norman Hansen, hereby declare as follows:
1. I am over 18 years of age and a resident of California. I am a named plaintiff in
the above-captioned case. Ihave personal knowledge of the facts and statements set forth in this
declaration, and if called upon to testify, I could and would competently testify thereto.
2. I was employed by Defendant Biscomerica Corp. (“Biscomerica”) in an hourly-
paid, non-exempt position from approximately 1996 t0 present. I decided to seek legal advice
about my work experiences with Biscomerica and about pursuing my grievances. I contacted
Lawyersfor Justice, PC and spoke with attorneys there. I wanted to d0 whatever I could t0 make
10 sure Biscomerica paid me and other employees what was owed t0 us for all hours worked and
11 non-compliant meal and rest breaks. After speaking with the attorneys, I investigated complex
PC
203
Suite
203
12 wage-and-hour lawsuits on my own and did some research into the leading class action and
JUSTICE,
1
9
13 employment law firms in California for approximately 7 hours. Thereafter, I consulted with the
Avenue,
California
14 attorneys at Lawyersfor Justice, PC for 6 hours to discuss my situation, complex wage-and-hour
Arden
15 class actions and representative actions under the Private Attorneys General Act (“PAGA”) in
Glendale,
LAWYERSfor
West
16 general, and what it meant to be a named plaintiff and PAGA representative.
410
17 3. I have spent over 13 hours meeting With my attorneys and fulfilling my
18 responsibilities as a PAGA representative in this case, which included gathering documents
19 concerning my employment with Biscomerica, reviewing documents with my attorneys and
20 answering their questions, and providing guidance regarding the work performed by non-exempt
21 employees, and helping develop a strategy as t0 what documents and information to obtain from
22 Biscomerica. I frequently checked in with my attorneys and their staff to make sure that they
23 had my most current information and any additional information that I had obtained.
24 4. As the case progressed, I was available to answer any questions my attorneys had,
25 and available to speak and meet with them whenever they needed me. I responded t0 my
26 attorneys as quickly as possible and gave them as much information and identified as many
27 documents as I could. I spent at least 12 additional hours speaking with my attorneys about the
28 case, identifying potential witnesses, providing my attorneys with documents and information
1
DECLARATION OF DEXTER NORMAN HANSEN
Document Filed Date
December 28, 2022
Case Filing Date
October 15, 2019
Category
Employment - Complex
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Edwin Aiwazian (SBN 232943) F i L E D > Arby Aiwazian (SBN 269827) :sLJPERIOR COURT .02: CALIFORNIA Joanna Ghosh (SBN 272479) COUNTY 0F SAN BERNAHmNo SAN BERNARDMO mmmm- LAWYERS for JUSTICE, PC 410 West Arden Avenue, Suite 203 Glendale, California 91203 DEC 2 8 2022 Tel: (818) 265-1020 / Fax: (818) 265-1021 Attorneysfor Plaintiffs 337“” PAOLA INigUE «,‘Deputv SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 10 BRIANNA FLORES, TANIA ESTREMERA, Case N0.: CIVDSI9308 14 individually, and 0n behalf 0f other members 11 PC of the general public similarly situated; Honorable David S. Cohn 203 DEXTER NORMAN HANSEN, individually, Department $26 12 Suite 91203 and 0n behalf of the other aggrieved JUSTICE, employees pursuant to the California Private CLASS ACTION 13 Attorneys General Act; Avenue, California DECLARATION OF DEXTER for 14 Plaintiffs, NORMAN HANSEN IN SUPPORT OF Arden PLAINTIFFS’ MOTION FOR FINAL 15 West Glendale, vs. APPROVAL OF CLASS ACTION LAWYERS 16 SETTLEMENT, ATTORNEYS FEES 410 BISCOMERICA CORR, a California AND COSTS, AND ENHANCEMENT corporation; and DOES through 100, 17 1 AWARDS inclusive, [Notice of Motion and Motion for 18 Final Approval 0f Class Action Settlement; Defendants. Declaration of Proposed Class Counsel (Ed- 19 win Aiwazian); Declarations of Proposed Class Re resentatives (Tania Estremera, 20 Brianna and [Proposed] Order filed lores); concurrently herewith] January 20, 2023 21 D : Tiara: 10:00 a.m. 22 Department: $26 23 Complaint Filed: October 15, 2019 FAC Filed: July 28, 2021 24 Trial Date: None Set 25 26 27 28 DECLARATION OF DEXTER NORMAN HANSEN \J V DECLARATION 0F DEXTER NORMAN HANSEN I, Dexter Norman Hansen, hereby declare as follows: 1. I am over 18 years of age and a resident of California. I am a named plaintiff in the above-captioned case. Ihave personal knowledge of the facts and statements set forth in this declaration, and if called upon to testify, I could and would competently testify thereto. 2. I was employed by Defendant Biscomerica Corp. (“Biscomerica”) in an hourly- paid, non-exempt position from approximately 1996 t0 present. I decided to seek legal advice about my work experiences with Biscomerica and about pursuing my grievances. I contacted Lawyersfor Justice, PC and spoke with attorneys there. I wanted to d0 whatever I could t0 make 10 sure Biscomerica paid me and other employees what was owed t0 us for all hours worked and 11 non-compliant meal and rest breaks. After speaking with the attorneys, I investigated complex PC 203 Suite 203 12 wage-and-hour lawsuits on my own and did some research into the leading class action and JUSTICE, 1 9 13 employment law firms in California for approximately 7 hours. Thereafter, I consulted with the Avenue, California 14 attorneys at Lawyersfor Justice, PC for 6 hours to discuss my situation, complex wage-and-hour Arden 15 class actions and representative actions under the Private Attorneys General Act (“PAGA”) in Glendale, LAWYERSfor West 16 general, and what it meant to be a named plaintiff and PAGA representative. 410 17 3. I have spent over 13 hours meeting With my attorneys and fulfilling my 18 responsibilities as a PAGA representative in this case, which included gathering documents 19 concerning my employment with Biscomerica, reviewing documents with my attorneys and 20 answering their questions, and providing guidance regarding the work performed by non-exempt 21 employees, and helping develop a strategy as t0 what documents and information to obtain from 22 Biscomerica. I frequently checked in with my attorneys and their staff to make sure that they 23 had my most current information and any additional information that I had obtained. 24 4. As the case progressed, I was available to answer any questions my attorneys had, 25 and available to speak and meet with them whenever they needed me. I responded t0 my 26 attorneys as quickly as possible and gave them as much information and identified as many 27 documents as I could. I spent at least 12 additional hours speaking with my attorneys about the 28 case, identifying potential witnesses, providing my attorneys with documents and information 1 DECLARATION OF DEXTER NORMAN HANSEN