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SUPERIOR COURT OF CALIFORNIA
Edwin Aiwazian (SBN 232943) COUNTY QF- SAN BERNARDINO
Arby Aiwazian (SBN 269827)
Joanna Ghosh (SBN 272479)
Mar? 1 3.. Zflzie
(SBN 348044)
Selena Matavosian
#UJN LAWYERSfor JUSTICE, PC 5 7.
[:45
410 West Arden Avenue, Suite 203 BY 74%,; flip”
Glendale, California 91203
fl
ABRIANNA RODR'IGUEZTDEPMY
Tel: (818) 265-1020 / Fax: (818) 265-1021
Attorneysfor Plaintiffs and the Class
\OWQONUI
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
ERNIE VALDEZ, individually, and on behalf Case No.1 CIVDSI920211 (Lead)
10 CIVDSl925029)
0f other members of the general public (Consolidated With
similarly situated; FELIX ONTIVEROS,
PC 11
individually, and 0n behalf of other members Honorable Joseph T. Ortiz
203
of the general public similarly situated and on Department S 1 7
203 12
Suite
behalf of other aggrieved employees pursuant
1
JUSTICE,
9 to the California Private Attorneys General CLASS ACTION
13
Avenue, Act,
California
DECLARATION OF JOANNA GHOSH
14 IN SUPPORT OF PLAINTIFFS’ MOTION
Plaintiff,
Arden
FOR FINAL APPROVAL OF CLASS
15
LAWYERSfor
West
Glendale,
vs. ACTION SETTLEMENT, ATTORNEYS’
FEES AND COSTS, AND
16 ENHANCEMENT AWARDS
410 COASTAL PACIFIC FOOD
DISTRIBUTORS, INC., a California
17
corporation; and DOES 1 through 100, [Notice 0f Motion and Motion for Final
inclusive, Approval of Class Action Settlement,
18
Attorneys’ Fees and Costs, and Enhancement
Defendants. Awards; Declaration of Class Representatives
19
(Ernie Valdez and Felix Ontiveros);
Declaration of Settlement Administrator
20 (Yami Burns); and [Proposed] Final
Approval Order and Judgment filed
21
concurrently herein]
22 Date: April 2, 2024
Time: 1:30 pm.
23
Department: S17
24 Valdez Complaint Filed: July 12, 2019
Ontiveros Complaint Filed: August 21, 2019
25
Trial Date: None Set
26
27
28
DECLARATION OF JOANNA GHOSH IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS
ACTION SETTLEMENT, ATTORNEYS’ FEES AND COSTS, AND ENHANCEMENT AWARDS
DECLARATION OF JOANNA GHOSH
I, Joanna Ghosh, hereby declare as follows:
1. I am an attorney licensed to practice law in
the State of California. I am a member
of Lawyers for Justice, PC, attorneys of record for Plaintiffs Ernie Valdez and Felix Ontiveros
(together, “Plaintiffs”) and the Class in the above-captioned matter.
The facts set forth in this
declaration are within my personal knowledge or based on information and
belief, and, if called
as a witness, I could and would competently testi
\OOOQON
fy as follows.
PRELIMINARY APPROVAL 0F SETTLEMENT
2. On November 28, 2023, in Department Sl7 of the above-entitled Court,
10 the Honorable Joseph T. Ortiz
preliminarily approved the Joint Stipu
lation of Class Action and
PC 11 PAGA Settlement and Release (“Settlement,” “Agreement,”
203 or “Settlement Agreement”) entered
12 into between
Suite
91203 Plaintiffs and Defendant Coastal Pacific Food
JUSTICE, Distributors, Inc., (“Defendant”)
13 (together with Plaintiffs, the “Parties”)
Avenue,
, and conditionally certified
California
the Class for settlement
14 purposes. The Court preliminarily
appointed Plaintiffs Ernie Valdez and
Arden
Felix Ontiveros as the
Glendale, 15 representatives of the Class (“Class
LAWYERSfor
West Representative”). The Court also preliminarily appointed
0
1 16 and designated Lawyers for
4 Justice, PC as counsel for the Class (“Class Coun
sel”).
The Court
17 approved and ordered the mailing
of the Notice of Class Action Settleme
nt (“Class Notice”),
18 adopted the notice, opt-out, and objec
tion procedures, and ordered their
implementation. The
19 Court appointed Phoenix Settlement
Administrators (“Phoenix” or “Settlem
ent Administrafor”)
20 to serve as the third-party settl
ement administrator and handle
the notice and settlement
21 administration process.
22 3. As of the date of filing the accompanying Motion
for Final Approval of Class
23 Action Settlement, Attomeys’ Fees
and Costs, and Enhancement Awards
(“Motion for Final
24 Approval"), no Class Members have objected to the Class Settlement or the reque
st for Attomeys’
25 Fees and Costs, Enhancement
Awards, Settlement Administration
Costs, or allocation for
26 penalties under the Private
Attorneys General Act of 2004, California Labor Code
section 2698,
27 et seq. (“PAGA”).
28 ///
l
DECLARATION OF JOANNA GHOSH 1N SUPP
ORT 0F PLAINTIFFS’ MOTION FOR FINAL
ACTION SETTLEMENT, ATTORNEYS’ FEES APPROVAL OF CLASS
AND COSTS, AND ENHANCEM ENT AWARDS
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‘ r a F J r , SUPERIOR COURT OF CALIFORNIA Edwin Aiwazian (SBN 232943) COUNTY QF- SAN BERNARDINO Arby Aiwazian (SBN 269827) Joanna Ghosh (SBN 272479) Mar? 1 3.. Zflzie (SBN 348044) Selena Matavosian #UJN LAWYERSfor JUSTICE, PC 5 7. [:45 410 West Arden Avenue, Suite 203 BY 74%,; flip” Glendale, California 91203 fl ABRIANNA RODR'IGUEZTDEPMY Tel: (818) 265-1020 / Fax: (818) 265-1021 Attorneysfor Plaintiffs and the Class \OWQONUI SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO ERNIE VALDEZ, individually, and on behalf Case No.1 CIVDSI920211 (Lead) 10 CIVDSl925029) 0f other members of the general public (Consolidated With similarly situated; FELIX ONTIVEROS, PC 11 individually, and 0n behalf of other members Honorable Joseph T. Ortiz 203 of the general public similarly situated and on Department S 1 7 203 12 Suite behalf of other aggrieved employees pursuant 1 JUSTICE, 9 to the California Private Attorneys General CLASS ACTION 13 Avenue, Act, California DECLARATION OF JOANNA GHOSH 14 IN SUPPORT OF PLAINTIFFS’ MOTION Plaintiff, Arden FOR FINAL APPROVAL OF CLASS 15 LAWYERSfor West Glendale, vs. ACTION SETTLEMENT, ATTORNEYS’ FEES AND COSTS, AND 16 ENHANCEMENT AWARDS 410 COASTAL PACIFIC FOOD DISTRIBUTORS, INC., a California 17 corporation; and DOES 1 through 100, [Notice 0f Motion and Motion for Final inclusive, Approval of Class Action Settlement, 18 Attorneys’ Fees and Costs, and Enhancement Defendants. Awards; Declaration of Class Representatives 19 (Ernie Valdez and Felix Ontiveros); Declaration of Settlement Administrator 20 (Yami Burns); and [Proposed] Final Approval Order and Judgment filed 21 concurrently herein] 22 Date: April 2, 2024 Time: 1:30 pm. 23 Department: S17 24 Valdez Complaint Filed: July 12, 2019 Ontiveros Complaint Filed: August 21, 2019 25 Trial Date: None Set 26 27 28 DECLARATION OF JOANNA GHOSH IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT, ATTORNEYS’ FEES AND COSTS, AND ENHANCEMENT AWARDS DECLARATION OF JOANNA GHOSH I, Joanna Ghosh, hereby declare as follows: 1. I am an attorney licensed to practice law in the State of California. I am a member of Lawyers for Justice, PC, attorneys of record for Plaintiffs Ernie Valdez and Felix Ontiveros (together, “Plaintiffs”) and the Class in the above-captioned matter. The facts set forth in this declaration are within my personal knowledge or based on information and belief, and, if called as a witness, I could and would competently testi \OOOQON fy as follows. PRELIMINARY APPROVAL 0F SETTLEMENT 2. On November 28, 2023, in Department Sl7 of the above-entitled Court, 10 the Honorable Joseph T. Ortiz preliminarily approved the Joint Stipu lation of Class Action and PC 11 PAGA Settlement and Release (“Settlement,” “Agreement,” 203 or “Settlement Agreement”) entered 12 into between Suite 91203 Plaintiffs and Defendant Coastal Pacific Food JUSTICE, Distributors, Inc., (“Defendant”) 13 (together with Plaintiffs, the “Parties”) Avenue, , and conditionally certified California the Class for settlement 14 purposes. The Court preliminarily appointed Plaintiffs Ernie Valdez and Arden Felix Ontiveros as the Glendale, 15 representatives of the Class (“Class LAWYERSfor West Representative”). The Court also preliminarily appointed 0 1 16 and designated Lawyers for 4 Justice, PC as counsel for the Class (“Class Coun sel”). The Court 17 approved and ordered the mailing of the Notice of Class Action Settleme nt (“Class Notice”), 18 adopted the notice, opt-out, and objec tion procedures, and ordered their implementation. The 19 Court appointed Phoenix Settlement Administrators (“Phoenix” or “Settlem ent Administrafor”) 20 to serve as the third-party settl ement administrator and handle the notice and settlement 21 administration process. 22 3. As of the date of filing the accompanying Motion for Final Approval of Class 23 Action Settlement, Attomeys’ Fees and Costs, and Enhancement Awards (“Motion for Final 24 Approval"), no Class Members have objected to the Class Settlement or the reque st for Attomeys’ 25 Fees and Costs, Enhancement Awards, Settlement Administration Costs, or allocation for 26 penalties under the Private Attorneys General Act of 2004, California Labor Code section 2698, 27 et seq. (“PAGA”). 28 /// l DECLARATION OF JOANNA GHOSH 1N SUPP ORT 0F PLAINTIFFS’ MOTION FOR FINAL ACTION SETTLEMENT, ATTORNEYS’ FEES APPROVAL OF CLASS AND COSTS, AND ENHANCEM ENT AWARDS