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.
Preview
V \r
Edwin Aiwazian (SBN 232943) F 3 L E D
Arby Aiwazian (SBN 269827) RUPERtog QOUR'TgElgfik‘laFgfigm
Joanna Ghosh (SBN 272479) “gk’figééfifiéfim
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LAWYERSfor JUSTICE, PC '
410 West Arden Avenue, Suite 203 n ‘
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Glendale, California 91203
MR 2021'
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265-1020 / Fax: (818) 265-1021 ~
Tel: (818)
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DEPUTY
.4
Attorneysfor Plaintiffs EDRM M, PORTILLO.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10 Case No.: CIVDSl930814
BRIANNA FLORES, TANIA ESTREMERA,
individually, and on behalf of other members
11
of the general public similarly situated; Honorable David S. Cohn
PC
203
DEXTER NORMAN HANSEN, individually, Department $26
12 ,
Sulte
and on behalf of the other aggrieved aw,-
CLASS ACTION
)
91203
JUSTICE,
employees pursuant to the California Private ‘
13
Attorneys General Act;
Avenue
Califomia
DECLARATION OF DEXTER
for
14 Plaintiffs, NORMAN HANSEN IN SUPPORT OF
Arden
PLAINTIFFS’ MOTION FOR
Glendale,
15
vs. PRELIMINARY APPROVAL OF CLASS
LAWYERS
West
ACTION SETTLEMENT
16
410
BISCOMERICA CORR, a California
corporation; and DOES 1 through 100, [Notice of Motion and Motion for
17 Preliminary Approval of Class Action
inclusive,
Settlement; Declaration of Proposed Class
18 Defendants. Counsel (Edwin Aiwazian); Declarations of
Proposed Class Representatives (Tania
19 Estremera, Brianna Flores); and [Proposed]
Order filed concurrently herewith]
20
D_ate: April 29, 2022
21 Tune: 10:00 am.
Department: 326
22
Complaint Filed: October 20 1 9
15,
23
FAC Filed: July 28, 2021
Trial Date: None Set
24
25
26
27
28
DECLARATION OF DEXTER NORMAN HANSEN
V \V
DECLARATION OF DEXTER NORMAN HANSEN
I, Dexter Norman Hansen, hereby declare as follows:
1. I am over 18 years of age and a resident 0f California. I am a named plaintiff in
the above-captioned case. I have 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 t0 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 do whatever I could to make
10 sure Biscomerica paid me and other employees what was owed to us for all hours worked and
11 non-compliant meal and rest breaks. After speaking with the attorneys, I investigated complex
PC
203
12 wage-and-hour lawsuits on my own and did some research into the leading class action and
Suite
91203
consulted with the
JUSTICE,
13 employment law firms in California for approximately 7 hours. Thereafter, I
Avenue,
California
14 attorneys at Lawyersfor Justice, PC for 6 hours to discuss my situation, complex wage—and-hour
for
Arden
15 class actions and representative actions under the Private Attorneys General Act (“PAGA”) in
Glendale,
West
LAWYERS
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 to 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 to 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
April 21, 2022
Case Filing Date
October 15, 2019
Category
Employment - Complex
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V \r Edwin Aiwazian (SBN 232943) F 3 L E D Arby Aiwazian (SBN 269827) RUPERtog QOUR'TgElgfik‘laFgfigm Joanna Ghosh (SBN 272479) “gk’figééfifiéfim " msmm LAWYERSfor JUSTICE, PC ' 410 West Arden Avenue, Suite 203 n ‘ a1 Glendale, California 91203 MR 2021' " ~ 265-1020 / Fax: (818) 265-1021 ~ Tel: (818) ¥ Mm- \ . ‘ Mza DEPUTY .4 Attorneysfor Plaintiffs EDRM M, PORTILLO. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 10 Case No.: CIVDSl930814 BRIANNA FLORES, TANIA ESTREMERA, individually, and on behalf of other members 11 of the general public similarly situated; Honorable David S. Cohn PC 203 DEXTER NORMAN HANSEN, individually, Department $26 12 , Sulte and on behalf of the other aggrieved aw,- CLASS ACTION ) 91203 JUSTICE, employees pursuant to the California Private ‘ 13 Attorneys General Act; Avenue Califomia DECLARATION OF DEXTER for 14 Plaintiffs, NORMAN HANSEN IN SUPPORT OF Arden PLAINTIFFS’ MOTION FOR Glendale, 15 vs. PRELIMINARY APPROVAL OF CLASS LAWYERS West ACTION SETTLEMENT 16 410 BISCOMERICA CORR, a California corporation; and DOES 1 through 100, [Notice of Motion and Motion for 17 Preliminary Approval of Class Action inclusive, Settlement; Declaration of Proposed Class 18 Defendants. Counsel (Edwin Aiwazian); Declarations of Proposed Class Representatives (Tania 19 Estremera, Brianna Flores); and [Proposed] Order filed concurrently herewith] 20 D_ate: April 29, 2022 21 Tune: 10:00 am. Department: 326 22 Complaint Filed: October 20 1 9 15, 23 FAC Filed: July 28, 2021 Trial Date: None Set 24 25 26 27 28 DECLARATION OF DEXTER NORMAN HANSEN V \V DECLARATION OF DEXTER NORMAN HANSEN I, Dexter Norman Hansen, hereby declare as follows: 1. I am over 18 years of age and a resident 0f California. I am a named plaintiff in the above-captioned case. I have 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 t0 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 do whatever I could to make 10 sure Biscomerica paid me and other employees what was owed to us for all hours worked and 11 non-compliant meal and rest breaks. After speaking with the attorneys, I investigated complex PC 203 12 wage-and-hour lawsuits on my own and did some research into the leading class action and Suite 91203 consulted with the JUSTICE, 13 employment law firms in California for approximately 7 hours. Thereafter, I Avenue, California 14 attorneys at Lawyersfor Justice, PC for 6 hours to discuss my situation, complex wage—and-hour for Arden 15 class actions and representative actions under the Private Attorneys General Act (“PAGA”) in Glendale, West LAWYERS 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 to 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 to 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