Document for Victoria Tice, etc., v. Trader Joe’s Company

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                                1    Larry W. Lee (State Bar No. 228175)
                  Max W. Gavron (State Bar No. 291697)
             2    DIVERSITY LAW GROUP, P.C.
             3    515 S. Figueroa Street, Suite 1250
                  Los Angeles, CA 90071
             4    (213) 488-6555
                  (213) 488-6554 facsimile
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             6    William L. Marder (State Bar No. 170131)
                  Polaris Law Group
             7    501 San Benito Street, Suite 200
                  Hollister, CA 95023
             8    (831) 531-4214
             9    (831) 634-0333 facsimile

           10     Attorneys for Plaintiff and the Class
           11                          SUPERIOR COURT OF THE STATE OF CALIFORNIA
           12                                  FOR THE COUNTY OF SANTA BARBARA
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                  VICTORIA TICE, as an individual and on                     Case No. 20CV00892
           14     behalf of all others similarly situated,
           15                                                                [Assigned to the Honorable Thomas P. Anderle,
                                    Plaintiff,                               Department 3]
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                           vs.                                               SUPPLEMENTAL DECLARATION OF
           17                                                                MAX W. GAVRON IN SUPPORT OF
           18                                                                PLAINTIFF’S MOTION TO COMPEL
                  TRADER JOE’S COMPANY, a California                         FURTHER DISCOVERY RESPONSES TO
           19     corporation; and DOES 1 through 50,                        PLAINTIFF’S SPECIAL
                  inclusive,                                                 INTERROGATORIES, SET THREE
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           21                       Defendants.                              Date:    February 8, 2022
                                                                             Time:    10:00 a.m.
           22                                                                Dept.:   SB Dept. 3

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                  SUPPLEMENTAL DECLARATION OF MAX W. GAVRON IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
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             2                                    DECLARATION OF MAX W. GAVRON
             3             I, Max W. Gavron, declare under penalty of perjury as follows:
             4             1.       I am an attorney at law duly admitted to practice before all courts in the State of
             5    California and am a member of the law firm of the Diversity Law Group, P.C., one of the
             6    attorneys of record for Plaintiff Victoria Tice (“Plaintiff”) in the above-entitled action. I have
             7    personal knowledge of the matters set forth herein, and if called upon as a witness to testify
             8    thereto, I could and would competently do so.
             9             2.       On February 24, 2021, the Court entered a stipulated protective order.
           10              3.       If the Court orders Defendant to produce the account and routing numbers, such
           11     that Plaintiff would be able to subpoena COMDATA, I would engage a third-party administrator
           12     to assist in the distribution of a notice to consumer to all aggrieved employees.               Defendant
           13     already produced the contact information of aggrieved employees after participating in a Belaire-
           14     West opt out process.      Thus, Plaintiff would be able to provide a notice to consumer to each
           15     aggrieved employee to in conjunction with any subpoena issued, and allow the appropriate
           16     amount of time to transpire prior to release of any records from COMDATA.
           17              4.         During the times Ms. Boyce reached out to contact me regarding the above
           18     proposed process, I was unavailable.
           19              I declare under penalty of perjury under the laws of the State of California and the United
           20     States that the foregoing is true and correct.
           21              Executed on February 1, 2022, at Los Angeles, California.
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           23                                                                   ___________________________
                                                                        Max W. Gavron
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                  SUPPLEMENTAL DECLARATION OF MAX W. GAVRON IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL