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Edwin Aiwazian (SBN 232943) ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
Arby Aiwazian (SBN 269827) COUNTY OF SAN BERNARDINO
Joanna Ghosh (SBN 272479) SAN BERNARDINO DISTRICT
Brian J. St. John (SBN 3041 12)
Selena Matavosian (SBN 348044) 10/30/2023 6:41 PM
LAWYERS for JUSTICE, PC DEPUTY
By: Sergio Villanueva,
410 West Arden Avenue, Suite 203
Glendale, California 91203
Tel: (818) 265-1020 / Fax: (818) 265-1021
Attorneysfor Plaintiffs
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SAN BERNARDINO
PC 11 ERNIE VALDEZ, individually, and on Case N0.: CIVDSI920211 (Consolidated With
203
behalf 0f other members 0f the general public CIVDS 1 925029)
Suite
91203
12 similarly situated; FELIX ONTIVEROS,
JUSTICE,
individually, and on behalf of other members Honorable Joseph T. Ortiz
Avenue,
13 of the general public similarly situated and Department S 1 7
California
on behalf 0f other aggrieved employees
for 14 pursuant t0 the California Private Attorneys CLASS ACTION
Arden
General Act,
West
Glendale,
15 SUPPLEMENTAL DECLARATION OF
LAWYERS
Plaintiffs, SELENA MATAVOSIAN IN SUPPORT
410
16 OF PLAINTIFFS’ MOTION FOR
V. PRELIMINARY APPROVAL OF CLASS
17 ACTION SETTLEMENT
COASTAL PACIFIC FOOD
18 DISTRIBUTORS, INC., a California [Plaintiffs’Supplemental Brief in Support 0f
corporation; and DOES 1 through 100, Plaintiffs’ Motion
for Preliminary Approval of
19 inclusive, Class Action Settlement; and [Revised
Proposed] Order filed concurrently herewith]
20 Defendants.
Date: November 28, 2023
21 Time: 1:30 p.m.
Department: S17
22
Valdez Complaint Filed: July 12, 2019
23 Ontiveros Complaint
Filed: August 2 1 20 1 9
,
24 Trial Date: None Set
25
26
27
28
SUPPLEMENTAL DECLARATION OF SELENA MATAVOSIAN IN SUPPORT OF
PLAINTIFF'S MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
DECLARATION OF SELENA MATAVOSIAN
I, Selena Matavosian, hereby declare as follows:
1. I am an attorney licensed t0 practice law in the State of California. I am a member
of Lawyers for Justice, PC, attorneys 0f record for Plaintiffs Ernie Valdez and Felix Ontiveros
(together, “‘Plaintiffs”). The facts set forth in this declaration are within my personal knowledge
0r based on information and belief, and if called as a witness, I could and would competently
testify thereto.
2. On September 1, 2023, Plaintiffs filed a Motion for Preliminary Approval 0f Class
Action Settlement (“Motion for Preliminary Approval”) and supporting documents seeking
10 approval of the settlement reached by Plaintiffs and Defendant Coastal Pacific Food
PC 11 Distributors, Inc. (“Defendant”) (collectively, the “‘Parties”).
203
Suite
91203
12 3. On September 26, 2023, the Court issued a tentative ruling (“September 26, 2023
JUSTICE,
Avenue,
13 Tentative Ruling”), Which became the Order 0f the Court, continuing the hearing date,
California
for 14 requesting supplemental information in support of the Motion for Preliminary Approval, and
Arden
West
Glendale,
15 setting a deadline for said supplemental information. A true and correct copy 0f the September
LAWYERS
410
16 26, 2023 Tentative Ruling is attached hereto as “EXHIBIT 1.” Specifically, the Court requested
17 the Parties to address the following:
18 a. T0 submit a supplemental declaration 0f Selena Matavosian in support of
19 the Motion for Preliminary Approval, containing a valuation of the claims;
20 b. T0 provide the estimated number of aggrieved employees and the fairness
21 of their average payout;
22 c. T0 provide evidence that notice 0f the settlement has been provided t0 the
23 Labor and Workforce Development Agency (“LWDA”); and
24 d. T0 establish the complexity 0r labor-intensive nature of the case that
25 justifies the thirty-five percent (35%) request for attorneys’ fees.
26 ESTIMATE OF THE VALUE OF THE CLAIMS
27 4. By way of the above-captioned action, Plaintiffs alleged that Defendant has
28 violated the California Labor Code and Industrial Welfare Commission Wage Orders by
1
SUPPLEMENTAL DECLARATION OF SELENA MATAVOSIAN IN SUPPORT OF
PLAINTIFF'S MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
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Edwin Aiwazian (SBN 232943) ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA Arby Aiwazian (SBN 269827) COUNTY OF SAN BERNARDINO Joanna Ghosh (SBN 272479) SAN BERNARDINO DISTRICT Brian J. St. John (SBN 3041 12) Selena Matavosian (SBN 348044) 10/30/2023 6:41 PM LAWYERS for JUSTICE, PC DEPUTY By: Sergio Villanueva, 410 West Arden Avenue, Suite 203 Glendale, California 91203 Tel: (818) 265-1020 / Fax: (818) 265-1021 Attorneysfor Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO PC 11 ERNIE VALDEZ, individually, and on Case N0.: CIVDSI920211 (Consolidated With 203 behalf 0f other members 0f the general public CIVDS 1 925029) Suite 91203 12 similarly situated; FELIX ONTIVEROS, JUSTICE, individually, and on behalf of other members Honorable Joseph T. Ortiz Avenue, 13 of the general public similarly situated and Department S 1 7 California on behalf 0f other aggrieved employees for 14 pursuant t0 the California Private Attorneys CLASS ACTION Arden General Act, West Glendale, 15 SUPPLEMENTAL DECLARATION OF LAWYERS Plaintiffs, SELENA MATAVOSIAN IN SUPPORT 410 16 OF PLAINTIFFS’ MOTION FOR V. PRELIMINARY APPROVAL OF CLASS 17 ACTION SETTLEMENT COASTAL PACIFIC FOOD 18 DISTRIBUTORS, INC., a California [Plaintiffs’Supplemental Brief in Support 0f corporation; and DOES 1 through 100, Plaintiffs’ Motion for Preliminary Approval of 19 inclusive, Class Action Settlement; and [Revised Proposed] Order filed concurrently herewith] 20 Defendants. Date: November 28, 2023 21 Time: 1:30 p.m. Department: S17 22 Valdez Complaint Filed: July 12, 2019 23 Ontiveros Complaint Filed: August 2 1 20 1 9 , 24 Trial Date: None Set 25 26 27 28 SUPPLEMENTAL DECLARATION OF SELENA MATAVOSIAN IN SUPPORT OF PLAINTIFF'S MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT DECLARATION OF SELENA MATAVOSIAN I, Selena Matavosian, hereby declare as follows: 1. I am an attorney licensed t0 practice law in the State of California. I am a member of Lawyers for Justice, PC, attorneys 0f record for Plaintiffs Ernie Valdez and Felix Ontiveros (together, “‘Plaintiffs”). The facts set forth in this declaration are within my personal knowledge 0r based on information and belief, and if called as a witness, I could and would competently testify thereto. 2. On September 1, 2023, Plaintiffs filed a Motion for Preliminary Approval 0f Class Action Settlement (“Motion for Preliminary Approval”) and supporting documents seeking 10 approval of the settlement reached by Plaintiffs and Defendant Coastal Pacific Food PC 11 Distributors, Inc. (“Defendant”) (collectively, the “‘Parties”). 203 Suite 91203 12 3. On September 26, 2023, the Court issued a tentative ruling (“September 26, 2023 JUSTICE, Avenue, 13 Tentative Ruling”), Which became the Order 0f the Court, continuing the hearing date, California for 14 requesting supplemental information in support of the Motion for Preliminary Approval, and Arden West Glendale, 15 setting a deadline for said supplemental information. A true and correct copy 0f the September LAWYERS 410 16 26, 2023 Tentative Ruling is attached hereto as “EXHIBIT 1.” Specifically, the Court requested 17 the Parties to address the following: 18 a. T0 submit a supplemental declaration 0f Selena Matavosian in support of 19 the Motion for Preliminary Approval, containing a valuation of the claims; 20 b. T0 provide the estimated number of aggrieved employees and the fairness 21 of their average payout; 22 c. T0 provide evidence that notice 0f the settlement has been provided t0 the 23 Labor and Workforce Development Agency (“LWDA”); and 24 d. T0 establish the complexity 0r labor-intensive nature of the case that 25 justifies the thirty-five percent (35%) request for attorneys’ fees. 26 ESTIMATE OF THE VALUE OF THE CLAIMS 27 4. By way of the above-captioned action, Plaintiffs alleged that Defendant has 28 violated the California Labor Code and Industrial Welfare Commission Wage Orders by 1 SUPPLEMENTAL DECLARATION OF SELENA MATAVOSIAN IN SUPPORT OF PLAINTIFF'S MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT