Preview
V \I
Edwin Aiwazian (SBN 232943)
Arby Aiwazian (SBN 269827)
Joanna Ghosh (SBN 272479)
Annabel Blanchard (SBN 258 1 35)
LAWYERS for JUSTICE, PC
410 West Arden A venue, Suite 203
Glendale, California 91203 fl F L E D !
Tel: (818) 265-1 020 / Fax: (81 8) 265-1021
”FENCE COURT 0F CALIFORNIA,
\OOONONUI#DJN>—A
COUNTY 0F SAN BEHNAr-J;
. .
SAN ammuamma {>2sz'igsrgo
Attorneysfor Plalntlffs and the Class
’
z) r
.-
DEC K" ,5 232‘;
Richard D. Marca (SBN 127365)
JeffT. Olsen (SBN 283249) ...,..._,:>
}
W
‘
Christopher Milligan (SBN 21 1532) Mj’: f
W
.
_, 7,
J,
VARNER & BRANDT LLP PAOLA w: am}? Lu
‘ '
3750 University Ave., Ste. 610
Riverside, California 92501
Tel: (951) 274-7777 / Fax: (951) 274-7770
(SBN 291083)
Julie O'Dell
Andrew S. (SBN 296872)
Levine
LEWIS BRISBOIS BISGAARD & SMITH LLP
650 Town Center Drive, Suite 1400
Costa Mesa, California 92626
Tel: (714) 668-5549 / Fax: (714) 850-1030
Attorneysfor Defendant
SUPERIOR COURT OF THE STATE OF CALIFORNIA
NNNNNNNNNt—tr—Hp—tt—Ir—Ap—It—At—tr—t
FOR THE COUNTY OF SAN BERNARDINO
OOQONkh-hWNr—‘OOOOQOM-bWNHO
BRIANNA FLORES, TANIA ESTREMERA,
individually, and 0n behalf of other members 0f
the general public similarly situated;
NORMAN HANSEN, individually, and 0n
behalf 0f the other aggrieved employees
pursuant to the California Private Attorneys
General Act;
vs.
Plaintiffs,
DEXTER
w
Case No. CIVDSl930814
Honorable David
Department S-26
DECLARATION 0F JARROD SALINAS
REGARDING NOTICE AND
SETTLEMENT ADMINISTRATION
S. Cohn
BISCOMERICA CORR, a California Hearing Date: January 20, 2023
corporation; and DOES 1 through 100, Hearing Time: 10:00 am.
inclusive, Hearing Place: Department S-26
Defendants. Complaint Filed: October 2019 15,
FAC Filed: July 28, 2021
Trial Date: None Set
1
DECLARATION OF JARROD SALINAS REGARDING NOTICE AND SETTLEMENT ADMINISTRATION
V \4
DECLARATION OF JARROD SALINAS
I, JARROD SALINAS, declare as follows:
1. I am a Case Manager at Phoenix Settlement Administrators (“Phoenix”), the Court-
appointed Class Action Settlement Administrator. Ihave personal knowledge 0fthe facts stated herein
\DOOQONLI‘IADJNH
and, if called upon t0 testify, I could and would testify competently to such facts.
2. Phoenix was appointed by the Court to provide notice of the Settlement and class
administration duties in this action. Pursuant to the Settlement Agreement for this matter, Phoenix was
responsible for (i) preparing, printing, and mailing the Notice 0f Class Action Settlement in English
and Spanish (herein referred to as the “Notice”); (ii) responding t0 inquiries from Class Members; (iii)
determining the validity 0f Requests for Exclusion from the Settlement; (iv) calculating the Net
Settlement Amount, the Individual Settlement Payments, and the Individual PAGA Payments; (v)
issuing the Individual Settlement Payment checks and Individual PAGA Payment checks and
distributing them t0 Settlement Class Members and PAGA Members; (Vi) issuing the payment to Class
Counsel for Attorneys’ Fees and Costs, the Enhancement Award checks t0 named Plaintiffs, and the
employer/employee payroll taxes to the appropriate taxing authorities; (Vii) distributing the LWDA
Payment to the LWDA; and (viii) such other tasks as set forth in the Agreement or as the Parties
mutually agree or as the Court orders.
NNNNNNNNNr—‘r—dr—‘r—dr—dp—tflp—Ap—ap—t
OONQM¥WNHOKOOONONLAJ>WNHO
3. On May 5, 2022, Phoenix received the Court-approved Class Notice from Plaintiffs’
Counsel. The Class Notice advised Class Members 0ftheir right to opt out from the Settlement, object
t0 the Settlement, or d0 nothing, and the implications of each such action.
4. On July 20, 2022, Phoenix received a data file from Defense Counsel that contained
last known full names, last known addresses, last known telephone numbers, Social Security numbers
and employee ID numbers, start and end dates of employment for each Class Member during the Class
Period, and Covered Workweeks for each Class Member (“Class Data”). The final mailing list
contained 739 Class Members.
5. On July 25, 2022, Phoenix conducted a National Change of Address (“NCOA”) search
in an attempt t0 update the Class Data addresses as accurately as possible. A search 0f the NCOA
2
DECLARATION OF JARROD SALINAS REGARDING NOTICE AND SETTLEMENT ADMINISTRATION
Preview
V \I Edwin Aiwazian (SBN 232943) Arby Aiwazian (SBN 269827) Joanna Ghosh (SBN 272479) Annabel Blanchard (SBN 258 1 35) LAWYERS for JUSTICE, PC 410 West Arden A venue, Suite 203 Glendale, California 91203 fl F L E D ! Tel: (818) 265-1 020 / Fax: (81 8) 265-1021 ”FENCE COURT 0F CALIFORNIA, \OOONONUI#DJN>—A COUNTY 0F SAN BEHNAr-J; . . SAN ammuamma {>2sz'igsrgo Attorneysfor Plalntlffs and the Class ’ z) r .- DEC K" ,5 232‘; Richard D. Marca (SBN 127365) JeffT. Olsen (SBN 283249) ...,..._,:> } W ‘ Christopher Milligan (SBN 21 1532) Mj’: f W . _, 7, J, VARNER & BRANDT LLP PAOLA w: am}? Lu ‘ ' 3750 University Ave., Ste. 610 Riverside, California 92501 Tel: (951) 274-7777 / Fax: (951) 274-7770 (SBN 291083) Julie O'Dell Andrew S. (SBN 296872) Levine LEWIS BRISBOIS BISGAARD & SMITH LLP 650 Town Center Drive, Suite 1400 Costa Mesa, California 92626 Tel: (714) 668-5549 / Fax: (714) 850-1030 Attorneysfor Defendant SUPERIOR COURT OF THE STATE OF CALIFORNIA NNNNNNNNNt—tr—Hp—tt—Ir—Ap—It—At—tr—t FOR THE COUNTY OF SAN BERNARDINO OOQONkh-hWNr—‘OOOOQOM-bWNHO BRIANNA FLORES, TANIA ESTREMERA, individually, and 0n behalf of other members 0f the general public similarly situated; NORMAN HANSEN, individually, and 0n behalf 0f the other aggrieved employees pursuant to the California Private Attorneys General Act; vs. Plaintiffs, DEXTER w Case No. CIVDSl930814 Honorable David Department S-26 DECLARATION 0F JARROD SALINAS REGARDING NOTICE AND SETTLEMENT ADMINISTRATION S. Cohn BISCOMERICA CORR, a California Hearing Date: January 20, 2023 corporation; and DOES 1 through 100, Hearing Time: 10:00 am. inclusive, Hearing Place: Department S-26 Defendants. Complaint Filed: October 2019 15, FAC Filed: July 28, 2021 Trial Date: None Set 1 DECLARATION OF JARROD SALINAS REGARDING NOTICE AND SETTLEMENT ADMINISTRATION V \4 DECLARATION OF JARROD SALINAS I, JARROD SALINAS, declare as follows: 1. I am a Case Manager at Phoenix Settlement Administrators (“Phoenix”), the Court- appointed Class Action Settlement Administrator. Ihave personal knowledge 0fthe facts stated herein \DOOQONLI‘IADJNH and, if called upon t0 testify, I could and would testify competently to such facts. 2. Phoenix was appointed by the Court to provide notice of the Settlement and class administration duties in this action. Pursuant to the Settlement Agreement for this matter, Phoenix was responsible for (i) preparing, printing, and mailing the Notice 0f Class Action Settlement in English and Spanish (herein referred to as the “Notice”); (ii) responding t0 inquiries from Class Members; (iii) determining the validity 0f Requests for Exclusion from the Settlement; (iv) calculating the Net Settlement Amount, the Individual Settlement Payments, and the Individual PAGA Payments; (v) issuing the Individual Settlement Payment checks and Individual PAGA Payment checks and distributing them t0 Settlement Class Members and PAGA Members; (Vi) issuing the payment to Class Counsel for Attorneys’ Fees and Costs, the Enhancement Award checks t0 named Plaintiffs, and the employer/employee payroll taxes to the appropriate taxing authorities; (Vii) distributing the LWDA Payment to the LWDA; and (viii) such other tasks as set forth in the Agreement or as the Parties mutually agree or as the Court orders. NNNNNNNNNr—‘r—dr—‘r—dr—dp—tflp—Ap—ap—t OONQM¥WNHOKOOONONLAJ>WNHO 3. On May 5, 2022, Phoenix received the Court-approved Class Notice from Plaintiffs’ Counsel. The Class Notice advised Class Members 0ftheir right to opt out from the Settlement, object t0 the Settlement, or d0 nothing, and the implications of each such action. 4. On July 20, 2022, Phoenix received a data file from Defense Counsel that contained last known full names, last known addresses, last known telephone numbers, Social Security numbers and employee ID numbers, start and end dates of employment for each Class Member during the Class Period, and Covered Workweeks for each Class Member (“Class Data”). The final mailing list contained 739 Class Members. 5. On July 25, 2022, Phoenix conducted a National Change of Address (“NCOA”) search in an attempt t0 update the Class Data addresses as accurately as possible. A search 0f the NCOA 2 DECLARATION OF JARROD SALINAS REGARDING NOTICE AND SETTLEMENT ADMINISTRATION