Motion for Summary Judgment in YVONNE COVARRUBIAS VS MACY'S CORPORATE SERVICES, I| Trellis.Law

On March 08, 2016 a Motion-Secondary was filed involving a dispute between Covarrubias, Yvonne, Zahabi, Atieh, and Does 1 Through 100, Inclusive, Macy'S West Stores, Inc., Macy'S West Stores, Inc., An Ohio Corporation, for (15) Unlimited Other Employment in the District Court of San Mateo County.

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FILED
SAN MATEO COUNTY
Scott Edward Cole, Esq. (S.B. #160744)
Corey B. Bennett, Esq. (S.B. #267816) JUL 17 2017
SCOTT COLE & ASSOCIATES, APC
1970 Broadway, Ninth Floor
Oakland, California 94612
clerk o Sr”
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Telephone: (510) 891 -9800 By
Facsunile: (510) 891-7030
Email: scole@scalaw.com
Email: cbennett scalaw.com
Web: www.sca aw.com
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Attorneys for Representative Plaintiffs
and the Aggrieved Employees

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
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H YVONNE COVARRUBIAS, and Case No. CIV537692
ATIEH ZAHABI, individually, and on
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aggrieved employees, PLAINTIFFS’ POINTS AND
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Plaintiffs, DEFENDANT’ S MOTION FOR SUMMARY
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Date: July 31, 2017
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Defendant. Time: 9:00 3.11:.
Dept: 21
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Plaintiffs’ P&A In Opposition to Defendant’s Motion for Summary Judgment
I. INTRODUCTION
Defendant Macy’s (“Defendant”) contends that Plaintiff Zahabi and Plaintiff Covarrubias

(“Plaintiffs”) are" not aggrieved employees, which entitles it to summary judgment. Plaintiffs

contend that the time spent waiting for and undergoing security checks was compensable under

California law. Plaintiffs further argue that such uncompensated time was not de minimis and
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therefore urge the Court to deny Defendant’s motion.

II. STATEMENT OF FACTS
Macy’s maintains a bag check policy under which Aggrieved Employees must submit to

inspections of any bags they are carrying (e.g., purses, backpacks, shopping bags, etc.) any time

they are leaving its stores.1 Defendant’s corporate witnesses conceded important facts regarding

this policy and the. violations resulting therefrom. First, there is no dispute that the policy is

cun'ently in use and all stores are required to follow it.2 Further, Macy’s admits that bag checks
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[—1 Og occur off-the-clock, after Aggrieved Employees clock out, but before they the premises.3
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daggas All Aggrieved Employees are informed of Macy’s bag check policy during orientation,
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aagage which point they are given access to an electronic employee handbook accessible through Macy’s
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m intranet.4 The policy requires Aggrieved Employees to enter and exit Defendant’s stores through
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designated employees doors.5 Upon exiting Macy’s-facilities, either at the end of their shifts or for
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meal and rest breaks, Aggrieved Employees must approach the employee doors, often located next

to the loss prevention ofﬁce, and present their bags to Macy’s loss prevention employees for
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inspection.6 Aggrieved Employees are required to hold their bags open and allow Macy’s to look

inside and, if asked by loss prevention, they were required to move items around to provide an

1
Exhibit “A,” Inspections and the Arrival and Departure of Associates Policy [MACYSOO7846-
007847]; Exhibit “B,” Employee Package Checks [MACYSOO7848-7849].
2
Exhibit “C,” Deposition of Khristopher‘
Hamlin (“Hamlin Depo;”) at 71:7-16; 72: 17-24; 36: 10—
38:13.
3
Exhibit “C,” Hamlin Depo. at 77:23-78:6; Exhibit “D,” Deposition of Bahrt Arellano
(“Arellano Depo.”) at 97: 1~25. While Mr. Arellano was de csed in the matter of Quinlan v.
Macy’s, the parties have stipulated to use discovery from t iat case here to avoid duplication of
discovery efforts. -

4
Exhibit “C,” Hamlin Depo. at 72:17~73:3; 32:14—25.
Exhibit “A,” Inspections and the Arrival and Departure of Associates Policy [MACYSOO7846~
5

007847 .

'6 Exhibit “E,” Deposition of Yvonne Covarrubias (“Covarrubias Depo.”) at 100:18—101z8.
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Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
unobstructed view of their bags’ contents.7 Those Aggrieved Employees who purchase and leave

the store with Macy’s goods must presenta receipt or otherwise prove to a member of loss
prevention that the merchandise was paid for.8 If no loss prevention employee is present at the

exit, Aggrieved Employees must seek one out to conduct the check? If multiple Aggrieved

Employees are leaving the store at the same time, they must wait in line to have their bags checked,

resulting in further delay. 1° In addition, to keep employees off-guard, Defendant also conducts bag
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checks at its general mall door entrances/exits.11 Aggrieved Employees who fail to comply with
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the policy are subject to discipline, up to and including termination.12

'Plaintiffs’ investigation reveals that Aggrieved Employees are frequently if not always

HO inspected, and are often delayed for considerable amounts of time. ‘3 While the length of the delays
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may vary, there is no dispute that Aggrieved Employees are not paid for this time for which, as set

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H '03In. LEGAL ARGUMENT
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A. LEGAL STANDARD ,

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BROADWAY, Summary judgment should not be granted where,,as here, Defendant has failed to meet its
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burden of persuasion that there is no triable issue of material fact. Aguilar v. Atlantic Richﬁeld
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\1 Ca, 25 Cal. 4th 826, 850 (2001). Defendant, as the moving party, is entitled to summary judgment
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only if all the papers submitted show that there are no triable issues as to any material facts and

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that the moving party is entitled to judgment as a matter of law. Cal. Code Civ. Proc. § 437(c)c.

NO The role of the trial court in a summary judgment motion is to determine whether triable issues of

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Exhibit “F,” Deposition of Atieh Zahabi (“Zahabi Depo.”) at 65: 17-66: 1.
3
Exhibit “C,” Hamlin Depo. at 107:7-1 11:22. -

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Exhibit “D,” Arellano Depo. at 98:7-1 1.
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Exhibit “E,” Covarrubias Depo. at 68:4-6923; Exhibit “F,” Zahabi Depo. at 96 :18-97:4.
NA ” Exhibit “C,” Hamlin Depo. at 1033-19; Exhibit “B,” Employee Package Checks
[MACYSOO7848-007849].
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Exhibit “A,” Inspections and the Arrival and De arture of Associates Policy [MACYSOO7846-
007847]; Exhibit “B,” Employee Package Checks FMACYSOO7848—7849].
13
NQ For instance, Plaintiffs Covarrubias and Zahabi complain of being delayed for up to four and
ﬁve minutes, respectively, as a result of bag checks. Exhibit “E,” Covanubias Depo. at 67:24-
N '4 69:3; Exhibit “F,” Zahabi Depo. at 69: 18-70:4. Other Aggrieved Employees whom Plaintiffs’
counsel has surveyed complain of even longer delays. Plaintiffs’ counsel will bring an expert
N 0° statistical analysis of the results of the survey disseminated to Aggiieved Employees to the
.
mediation.
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Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
fact exist, not to resolve those issues. Morgan v. F UJI Country USA, Inc., 34 Cal.App. 4th 127,

131 (1995). Due to the drastic nature of summary judgment and the importance of safeguarding
the right to trial, the moving party's evidence is to be strictly construed. Brantley v. Pisaro, 42 Cal.

App.4th 1591, 1601 (1996). A11 doubts are to be resolved in favor of the party opposing summary
judgment.
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Ferrell v.Southern Nev. Off—Road Enthusiast Ltd, 147 Cal.App.3d 309, 313 (1983).
The opposing party's affidavits or declarations are to be liberally construed. Fender v. Radin, 23

Cal.App.4th 1807, 1813 (1994). Theopposing party has no obligation to establish anything until
and unless the moving party has met its burden. Consumer Cause, Inc. v. Smilecare, 91

Cal.App.4th 454, ‘468 (2001). Ultimately, if there is evidence from which a jury could ﬁnd for the

opposing party, the motion should be denied.

Addressing the legal standard for granting summary judgment in Code of Civil Procedure
APC section 43 70 a leading practice text in California stated:

Considerable care must go into drafting the separate statement because the
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court has discretion to disregard matters not listed therein [citation].
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involved because the separate statement effectively concedes the
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materiality of whatever facts are included. Thus, ifa triableissue is raised
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as to any of the facts in your separate statement, the motion must be
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(Well & Brown, Cal. Practice Guide: Civil Procedure Before Trial (Rutter Group 2008) 10.951,
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p. 10—35 (Rev.#1 2008).). Accordingly, in order for Defendant’s Motion to succeed itmust

demonstrate that
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there exists no triab‘leissue of fact regarding any of Plaintiffs’ claims after
viewing all of the evidence in a light most favorable to Plaintiffs. As set forth below, Defendants
have failed to meet this burden.
B. PLAINTIFFS’ TIME WAITING FOR AND UNDERGOING SECURITY
CHECKS CONSTITUTE COMPENSABLE “HOURS WORKED”
The time Plaintiffs spent waiting for and undergoing security checks—from clock out to
the exit, until they were tmly free to leave and out of Defendant’s control——Was compensable under

California law. Defendant disagrees, relying heavily on one case currently on appeal, Frlekin v.

Apple Inc. , 2015 US. Dist. LEXIS 151937 (N .D. Cal. Nov. 7, 2015), and multiple distinguishable

cases upon which that very holding is based.

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Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
1. Frlekin Ignores Black Letter California Law,
Defendant argues Frlekin” is instructive, contending that Apple’s policy, “for all practical
purposes, is identical to Macy’s random package check policy.” See MSJ at p. 10. Frlekin holds
that bag check time is not compensable because it is not a'required work activity since employees
can avoid the activity by not bringing bags to work.
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It reaches this absurd conclusion by ignoring
the plain language of the controlling Wage Order. The IWC Wage Orders deﬁne “hours worked”

as (1) “the time during which an employee is subject to the control of an employer,” and (2)"‘a11

the time the employee is suffered or permitted to work, whether or not required to do so.” See 8

Cal. Code Regs. §'11070 112(6). These are separate, independent elements, either of which defines

H “hours worked” if met. Morillion, 22 Gal.4th at 582.
H Furthermore, Defendant overlooks Frlekin’s reliance on distinguishable cases involving

APC >4 commute time to support its conclusion that activities must be “required” in order to be
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compensable. Id. at *11-15. Commute time cases are inapposite for two reasons. First, employee
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commute time is ordinarily not compensable. Cal. Lab. Code commute time—
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§ 510(b). Second,
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unlike time spent in connection with bag checks—happens away from the workplace, before or
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after the workday, and away from employer supervision. In contrast, bag checks occur throughout
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the workday on the premises
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of and under the direct supervision of the employer, and therefore

are not comparable to commute time cases.

N'H 2.
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Plaintiffs and Aggrieved Employees Were Subject to Macy’s Control
During Bag Checks
The “control” prong imposes just one elemen : “control.” The very next clause of the same
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sentence in the deﬁnition uses the word “required.” 1d. Different meanings are presumed by the
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application of different words. Rashidi v. Maser, 60 Cal.4th 718, 725 (2014) (“[W]here the

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Legislature uses a different word or phrase in one part of a statute than it does in other sections . .

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. it must be presumed that the Legislature intended a different meaning”) (citation omitted). If the
“control” prong were intended to only encompass activities which the employer “required,” then
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N It should be noted that FrIekin is currently on appeal to the Ninth Circuit and, while oral argument was held on
July 11, 2017, the court has yet to issue a decision.
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Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
it would say so. Moreover, there is no logic in the deﬁnition only including, on the one hand, time

spent subject to employer control, if it was required, but, on the other hand, including all the time
the employee was suffered or permitted to work, whether it was required or not.

The level of employer control is the determinative factor (id. at 587), and “this is not an
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instance in which the relevant law or appropriate standard is unclear.” PeIz v. Abercrombie & Fitch
Stores, Inc., 2015 US. Dist. LEXIS 186789, *4 (CD. Cal. June 4, 2015) (denying employer’s
motion for summary judgment in bag check case). Plaintiffs and Aggrieved Employees were

subject to Macy’s control during bag checks because, even though they could engage in some

limited personal activities (e.g., chatting, using their cell phones, etc.), they could'not “effectively
use [the time] for their own purposes.” Mari/lion, 22 Cal.4th at 586 (citing Bono Enterprises, Inc.

v. Bradshmv, 32 Cal.App.4th 968, 975 (1995)). Plaintiffs could not, for example, buy food or

APC coffee from a nearby vendor, smoke a cigarette, enjoy the sunshine, drive his or her vehicle, or do
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any other personal activity that requires being outside of a Macy’s store. Pelz, 2015 US. Dist.
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and holding off—the-clock bag check waiting periods were compensable.)
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a. Defendant’s Sleight of Hand
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“Macy’s didn’t ‘require’ them to carry a bag .. ..” MSJ at 10 (emphasis in original). This
characterization asks the Court to only the to what
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see bag, as opposed is inside and why an

employee might want or
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need to carry it to work. Defendant describes its inspection policy as

“random” and something that employees “voluntarily submit to” by “choosing” to carry a bag to

work. This plainly ignores the fact that “in real life people bring stuff to work.”15 The Ninth Circuit

made this very point during the Frlekin oral argument. Here, Defendant asks the Court to believe

employee choice renders itspolicy lawful. Employees “choose” to bring food to eat on meal

breaks. Employees “choose” to bring a water bottle to drink from on rest breaks. Employees
“choose” to bring personal effects, medications, jackets and extra clothing, or any other number
of items that might not ﬁt into a wallet or small coin purse. It is not unreasonable for Defendant to

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See httns://www.youtube.com/watch?v=‘l‘ib9gRWPJ04 at 14:00.
.
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Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
compare an employee’s receipt with the contents of their Macy’s shopping bag. However,

Defendant conﬂates the “choice” of making a Macy’s clothing purchase on a break With carrying

a bag containing necessities—clothing layers to prepare for unusually hot or cold weather, foods

and liquids to sustain the httman body, and other things people need to manage their daily lives.

Plaintiffs did not personally experience searches on meal and rest breaks, but food bags
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and containers are still subject to search at the end of a shift (presumably when they are empty).

Would Defendant contend that, while California law requires employers to provide meal breaks,

an employee “voluntarily submits” to a bag search by bringing food? California law also imposes

requirements on employers to provide time and space‘for mothers to express breastmilk. Cal. Lab.

Code § 1030 et seq. Would bringing a breast pump and related items in a bag be about “employee
choice” and “personal convenience” such that it should be subject to search off—the-clock? The

APC law provides for meal breaks and breastfeeding accommodations because of their fundamental
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importance, not as opportunities for employers to cut corners. ‘
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Defendant’s sleight of hand directs the Court’s attention toward a simplified notion of
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employee choice and away from the actual character and impact of its bag search policy. Here,
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Plaintiffs were subject to Macy’s control during bag checks and such time constituted “hours
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worked” under the applicable Wage Order.

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3. Plaintiffs and Aggrieved Employees Were Suffered or Permitted to
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Work During Bag Checks
California law also deﬁnes “hours worked” as “all the time the employee issuffered or

permitted to work, whether or. not required to do so.” 8 Cal. Code Regs. § 11070 ﬁl2(G). This test

is separate and distinct from the “control” test and provides an “independent” basis for liability
under the Wage Order. Mendiola v. CPS Security Solutions, Inc. , 60 Cal.4th 833, 839 (2015).

Friekin held that the employees did not “work” during bag checks because (a) they “did

not conduct” the bag checks and merely “passively awaited” as the checks were conducted, and

(b) because the bag checks were not “integral and indispensable” parts of the employees’ job
duties. Frlekin at *33—34. This was error, as bag checks easily meet the “suffered or permitted to
work” test under California law.

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Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
a. Bag Cheeks Were “Work” Because They Were Exertion that
Benefited Defendant
First, the bag checks were “work” because they were exertion that beneﬁted Defendant.

See Befancourt v.Advantage Human Resourcing, Inc., 2014 US. Dist. LEXIS 123504, *17 (N .D.

Cal. Sept.
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3, 2014) (Black’s Law Dictionary defines “work” as “mental exertion to attain an end,

especially as controlled by and for the beneﬁt of an employer.”). As explained in Mendiola, “[A]n
employer, if he chooses, may hire a man to do nothing, or to do nothing but wait for something to
happen.” Mendiola, 60 Cal.4th at 840 (quoting Armour & Co. ‘vi Wautock, 323 US. 126, 133

(1944)). Even idle, “on-call” time may be compensable “work” if the time “beneﬁt[s] the

employer.” Id; see also id. at 841 (whether time is “primarily” for employer’s beneﬁt is a relevant

factor); cf Tennessee Coal, 321 US. at 598 (“work” includes “physical or mental exertion

APC (whether burdensome or not) controlled or required by the employer and pursued necessarily and
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primarily for the beneﬁt of the employer”). Moreover, if “immediate control” is exercised over an
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activity that “beneﬁt[s] -
the employer,” there is no question that the time “must be
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cited with approval in Mendiola, 60 Cal.4th at 841.

of “work.” They involve “exeition” or
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The bag checks meet this plain—language deﬁnition
“effort,” including
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ﬁnding a loss prevention employee, standing in line, presenting bags for
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inspection, opening intemal pockets, complying with employer directions, etc. The bag checks

“attain an end”——name1y, conﬁrming that employees are not stealing merchandise—which

beneﬁts Defendant by deterring and preventing theft, both present and future. See .Mendiola, 60

Cal.4th at 481 (theft—prevention activities “primarily beneﬁt” the employer). Furthermore, the?

bag checks not only involved “exertion” to “attain an end,” for the beneﬁt of Defendant, but also
involved “immediate control” by the employer. See Ghazaryan, 169 Cal.App.4th at 1535.

Consistent with Meudiola, the bag checks in this case were compensable “work.” Id.

.
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Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
h. Frlekin Improperly Relies on a Less Protective Federal
Standard that Finds No Support in California Law
Frlekin also holds that bag checks are not “wor ” because they are “peripheral activities”

with “no relationship” to the employees’ job responsibilities. Frlckin at *33. This argument is

factually and legally incorrect.

F actually, bag checks do relate to employees’ job responsibilities. Defendant’s employees
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must handle itsmerchandise in order to perform their duties (e.g., stocking shelves, ringing up

customers, processing returns, etc.). If Defendant’s employees were not required to have access to
its merchandise, bag checks would be unnecessary.

Legally, in holding that “peripheral activities” we non-compensable under California law,
Frlekin effectively imported the less-protective standard of the federal Portalito-Ilortal Act, under
which “preliminary and postliminary” activities are non-compensable. 29 U.S.C. § 254(a), cited
APC in Moriliion, 22 Cal.4th at 589; see also Murphy v. Kenneth Cole Productions, Inc, 40 Cal.4th
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1094 (2007) (California employment law is “to be construed broadly in favor of protecting
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workers”) (emphasis added).
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The Frlekin decision cites Integrity Staffing Solutions,
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135 S.Ct. 513, 518 (2014), which was a case out of Nevada involving the Fair Labor Standards
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Act, for the proposition that bag checks “lacked the integral or indispensable relationship to the
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employees’ job responsibilities.” Frlekin at *34. Although Frlekin was not applying federal law,

the standard it used mirrored it, leading to an outcome identical
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to Busk. _

This ruling contravened the California Supreme Court’s repeated admonition that the IWC
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has never adopted the federal standard for “hours worked.” ll/Iendiola, 60 Ca1.4th at 843; Morillion,
22 Ca1.4th at 590-92; Bono, 32 Cal.App.4th at 977; see‘also Martinez v. Combs, 49 Cal.4th 35, 68

(2010). This ruling also disregarded the lWC’s decision to amend the Wage Orders in 1947, “[i]n
response to” the enactment of the Portal-to-Portal Act, in order “to provide employees with greater

protection than federal law affords.” Martinez, 49 Cal.4th at 59-60. The ruling ignored the fact that

when the IWC wishes to adopt a federal standard, it knows how and does so explicitly, as shown

in, for example, Wage Order 4 itself. Morillion, 22 Ca1.4th at 592. Wage Order 4, which applies

to the health care industry, explicitly deﬁnes “hours worked” as being based on the federal

standard. 8 Cal. Code Regs. § 11040 112(K) (“Hours worked” means “the time during which an

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Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
>— employee is suffered or permitted to work for the employer, whether Or not required to do so, as

N interpreted in accordance with the provisions of the Fair Labor Standards Act.”) (emphasis
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added). Wage Order 7, which governs this case, contains no such qualifying language. 8 Cal. Code

L Regs. § 11070 1|2(G).

m Because California law “differ[s] substantially” from the federal standard (Morillion, 22

O‘ Cal.4th at 590, 594), Busk is not applicable to employee’s bag check claims under California law.
.

\l See Ceja—Corona v. CVSPharm., Inc., 2015 US. Dist. LEXIS 5118, *11 (ED. Cal. Jan. 14, 2015)

00 (state law security screening claims still viable in light of Busk)
KC C. PLAINTIFF S’ BAG CHECK TIME IS NOT DE MYNIMIS
Does California wage and hour law require employers to pay for all off-the-clock work that

the employer either knows or should know is occurring? This is a question currently pending

APC
before the California Supreme Court following the Ninth Circuit’s request in Troester v. Starbucks

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Defendant argues that the time Plaintiffs spent waiting for and undergoing back checks was
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de minimis. Whether work time is de minimis is analyzed under- a three—prong test that considers
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(l) the practical administrative difficulty of recording the additional time; (2) the aggregate amount
of compensable time; of the additional work. Lindow
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and (3) the regularity v. United States, 738

F.2d 1057, 1063 (9th Cir. 1984). The DLSE has ad0pted this test in evaluating claims under

California law. DLSE Opinion Letter 1994-02—03—3 at p. 4.

First, Defendant’s bag search policy is a loss prevention measure intended to catch and
deter theft. If the administrative difﬁculty of implementing this policy is justiﬁed by the loss it

prevents, then Defendant should either bear the minimal practical burden of repositioning time

clocks such that employees may clock out after waiting for and undergoing bag checks, or ﬁnd

another way to compensate employees for time spent under Defendant’s control and engaged in

an activity that solely beneﬁts Defendant; .

Second, the aggregate amount of compensable time was not de minimis. Defendant relies

on cases that favor weaker federal labor laws to California’s substantially more protective scheme.

For example, Labor Code § 510 provides, in pertinent part: “Any work in excess of eight hours in

-9-
Plaintiffs’ Opposition to Defendant’s Motion for Summary Judgment
one workday and, (my work in excess. of 4091101118 in anyone workweek and the-ﬁrst eight‘hours

:w‘orked 0n the seventh day of workin any one workvteek shall .be. compensated atetherate of no
less thantone‘ and one-half time's thei'egular rate 15 of pay for an‘ employee.” (emphasis added),

Humvee Defendant contends? that even teammates should be deemed 'd‘e mininiis. California’s

expansive
.xoﬁoe'xlmmfmwtou—r
regulatory framewbrk provides signiﬁiia'nt,protection 'd employees and ample

irISti'uction,for courts 'to IeSiSt,n10Vement toward “less protective approaches. This issue is currently.
’

under consideration by j(he Galiforiiia Supreme Celia. See; I'lfo‘esr, supra.

.‘Third, Defendant claims the additional work was not regu‘lari Plaintifﬂzahabi could not

recall the total number of searches, but identiﬁed Up to ﬁv’e'that she could. (SMUF $15, 20);

Similarly, Plaintiff “Covamlbi'asrecalled/roughly twenty, but‘eould'not: conclude it was not more.

(Ids at-"J 28),.
See lindow at 1063 (“Courts have granted relief for claims that might have been ‘

minimalm a daily basis but, when aggregate.d,3amounted fo‘asubSt’antial sum?’2and 5‘liappenI] with
aifai‘r‘ainoﬁnt Of regularity?)
mw 9461':

'IV.
COLE‘g

Case Info

Judge

Grandsaert, John L. Track Judge’s New Case

Case No.

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Document Filed Date

July 17, 2017

Case Filing Date

March 08, 2016

County

Parties

COVARRUBIAS, YVONNE Plaintiff
DOES 1 THROUGH 100, INCLUSIVE Defendant
GRAHAM, JEREMY A. Attorney for the Plaintiff
KATZ, STEVEN B Attorney for the Defendant
MACY'S WEST STORES, INC. Defendant
MACY'S WEST STORES, INC., AN OHIO CORPORATION Defendant
ZAHABI, ATIEH Plaintiff
Scott Cole Attorney
Matthew Bainer Attorneys for Plaintiffs
Corey Bennett Attorneys for Plaintiffs
Steven Stoltz Attorney
Teresa Allen Attorney
Matthew Russo Attorneys for Plaintiffs
David Mainzer Attorney
Kenneth Sulzer Attorneys for Plaintiffs
Hannah Salassi Attorney
Catherine Selin Attorney
Jeremy Apple Attorneys for Plaintiffs

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Motion-Secondary: YVONNE COVARRUBIAS VS MACY'S CORPORATE SERVICES, I

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