Motion-Secondary: PEOPLE OF THE STATE OF CALIFORNIA VS. UBER TECHNOLOGIES, INC., A DELAWARE CORPORATION ET AL

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                                1     GIBSON, DUNN & CRUTCHER LLP
                      THEODORE J. BOUTROUS, JR., SBN 132099
                2        tboutrous@gibsondunn.com
                      THEANE EVANGELIS, SBN 243570
                                                                                                                 ELECTRONICALLY
                3        tevangelis@gibsondunn.com
                      BLAINE H. EVANSON, SBN 254338                                                                 F  I  L   E  D
                4        bevanson@gibsondunn.com                                                                 Superior Court of California,
                                                                                                                  County of San Francisco
                      HEATHER L. RICHARDSON, SBN 246517
                5        hrichardson@gibsondunn.com                                                                  07/15/2020
                      333 South Grand Avenue                                                                     Clerk of the Court
                                                                                                                   BY: EDNALEEN ALEGRE
                6     Los Angeles, CA       90071-3197                                                                        Deputy Clerk
                      Telephone:     213.229.7000
                7     Facsimile:     213.229.7520
                8     Attorneys for Defendant
                        Uber Technologies, Inc.
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              10                             SUPERIOR COURT OF THE STATE OF CALIFORNIA

              11                                      FOR THE COUNTY OF SAN FRANCISCO

              12      PEOPLE OF THE STATE OF CALIFORNIA,                            CASE NO. CGC-20-584402
              13                        Plaintiff,                                  DECLARATION OF MICHAEL CHAN IN
                                                                                    SUPPORT OF UBER
              14               v.                                                   TECHNOLOGIES, INC.’S MOTION TO
                                                                                    STAY PROCEEDINGS
              15      UBER TECHNOLOGIES, INC., a Delaware
                      Corporation; LYFT, INC., a Delaware                           Hon. Ethan P. Schulman
              16      Corporation; and DOES 1-50, Inclusive,                        Dept. 302
              17                        Defendants.                                 HEARING:
                                                                                    Date:              August 6, 2020
              18                                                                    Time:              9:30 a.m.
              19                                                                    Action Filed:      May 5, 2020
                                                                                    Trial Date:        None Set
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      Gibson, Dunn &
      Crutcher LLP
                       DECLARATION OF MICHAEL CHAN IN SUPPORT OF MOTION TO STAY PROCEEDINGS – CASE NO. CGC-
                                                                              20-584402
                1              I, Michael Chan, declare as follows:
                2              1.       I am   currently   employed     as Lead    Paralegal,   Employment      Legal   for  Defendant    Uber
                3     Technologies,     Inc.  (“Uber”).    In  this position,   I support   the  attorneys   handling   employment      related

                4     litigation at Uber.
                5              2.       I make    this  declaration    in  support   of  Uber’s    Motion    to  Stay   Proceedings.      I  am
                6     authorized to make these statements on behalf of Uber.
                7              3.       The   information    set  forth  herein   is true  and  based   on  my   own    personal   knowledge
                8     (unless otherwise stated).      If called as a witness, I could and would competently and truthfully testify
                9     thereto.
              10               4.       In  my  current   position   at Uber,   I have  personal    knowledge     of pending    litigation  and

              11      arbitrations involving Uber.
              12               5.       At  this  time,  nearly   one  thousand    California    drivers  have   either  initiated  arbitration
              13      proceedings or been ordered to arbitrate claims against Uber, in which the drivers allege that they are
              14      misclassified and should be treated as employees.

              15               6.       At  this  time,  thousands    of  other  California   drivers   have   told  Uber   that they   plan  to
              16      initiate arbitration proceedings, in which the drivers allege that they are misclassified and should be
              17      treated as employees.
              18               I declare under penalty of perjury that the foregoing is true and correct.
              19               Executed on this 14th day of July, 2020, in San Francisco, California.

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              22                                                                                   Michael Chan
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      Gibson, Dunn &                                                              2
      Crutcher LLP
                       DECLARATION OF MICHAEL CHAN IN SUPPORT OF MOTION TO STAY PROCEEDINGS – CASE NO. CGC-
                                                                              20-584402