DECLARATION OF ROBERT OTTINGER IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND AWARDS OF ATTORNEYS’ FEES, COSTS, AND INCENTIVE PAYMENTS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Robert W. Ottinger (SBN 156825) [email protected]Daniel H. Galindo (SBN 322260) [email protected]THE OTTINGER FIRM, P.C. 535 Mission Street, 14 th Floor San Francisco, CA 94105 Telephone: (415) 325-2088 Facsimile: (212) 571-0505 Louis Benowitz (SBN 262300) [email protected]LAW OFFICES OF LOUIS BENOWITZ 9454 Wilshire Boulevard, Penthouse Beverly Hills, California 90212 Telephone: (310) 844-5141 Facsimile: (310) 492-4056 Attorneys for Plaintiffs, Jon Baughman, Betty Miles, Kristina Villegas And Yulia Zamora SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION JON BAUGHMAN, BETTY MILES, KRISTINA VILLEGAS, and YULIA ZAMAORA on behalf of themselves and all others similarly situated, Plaintiffs, vs. SOCIAL FINANCE, INC., [a Delaware Corporation], and DOES 1--50, inclusive, Defendants. Defendants. Case No. CGC-17-560700 [Assigned for All Purposes to the Honorable Anne-Christine Massullo, of Dept. 304] DECLARATION OF ROBERT OTTINGER IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND AWARDS OF ATTORNEYS’ FEES, COSTS, AND INCENTIVE PAYMENTS Hearing Information Date: March 1, 2019 Time: 2:00 p.m. Location: Department 304 Judge: Hon. Anne-Christine Massullo
Transcript
DECLARATION OF ROBERT OTTINGER IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND AWARDS OF
ATTORNEYS’ FEES, COSTS, AND INCENTIVE PAYMENTS
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Robert W. Ottinger (SBN 156825) [email protected] Daniel H. Galindo (SBN 322260) [email protected] THE OTTINGER FIRM, P.C. 535 Mission Street, 14th Floor San Francisco, CA 94105 Telephone: (415) 325-2088 Facsimile: (212) 571-0505
Louis Benowitz (SBN 262300) [email protected] LAW OFFICES OF LOUIS BENOWITZ 9454 Wilshire Boulevard, Penthouse Beverly Hills, California 90212 Telephone: (310) 844-5141 Facsimile: (310) 492-4056
Attorneys for Plaintiffs, Jon Baughman, Betty Miles, Kristina Villegas And Yulia Zamora
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
JON BAUGHMAN, BETTY MILES, KRISTINA VILLEGAS, and YULIA ZAMAORA on behalf of themselves and all others similarly situated,
Plaintiffs,
vs.
SOCIAL FINANCE, INC., [a Delaware Corporation], and DOES 1--50, inclusive, Defendants.
Defendants.
Case No. CGC-17-560700 [Assigned for All Purposes to the Honorable Anne-Christine Massullo, of Dept. 304]
DECLARATION OF ROBERT OTTINGER IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND AWARDS OF ATTORNEYS’ FEES, COSTS, AND INCENTIVE PAYMENTS
Hearing Information Date: March 1, 2019Time: 2:00 p.m.Location: Department 304Judge: Hon. Anne-Christine Massullo
DECLARATION OF ROBERT OTTINGER IN SUPPORT OF
PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND AWARDS OF ATTORNEYS’ FEES, COSTS, AND INCENTIVE PAYMENTS
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DECLARATION OF ROBERT W. OTTINGER
I, Robert Ottinger, declare as follows:
1. I am an attorney in good standing and duly admitted to the State Bar of California and
an attorney of record for Plaintiffs Jon Baughman, Betty Miles, Kristina Villegas, and Yulia Zamora
(collectively, “Plaintiffs”) in this action against Defendant Social Finance, Inc. (hereafter, “Defendant”
or “SoFi”).
2. My firm, The Ottinger Firm, P.C., is an employment law firm with offices in New York
and San Francisco. We have been focusing on employment law since 1999 and have represented
thousands of people over the years in various employment matters, including wage & hour class
actions.
3. Except for those matters stated on information and belief, which I am informed and
believe are true and correct, I have personal knowledge of all matters set forth herein. If called as a
witness, I could and would competently testify thereto.
4. I graduated from Loyola Law School and received my Juris Doctor in June 1991. I
received a B.A. degree from East Stroudsburg University in 1986. I have over 20 years of legal
practice experience since graduating from law school in 1991. I was admitted to practice in
California in December 1991, and in New York in 1996. I began my career by clerking for Judge
Robert M. Mallano of the California Superior Court in Los Angeles, California from December
1991 to 1993 and, from 1993 to 1995, working as a Deputy Attorney General for the California
Department of Justice where he handled criminal appeals and trials. From 1995 to 1997, I worked
as an Assistant Attorney General at the New York State Attorney General’s Office where I
handled employment and civil rights matters in federal court, including serving as lead trial counsel in
over twelve federal jury trials involving civil rights and employment discrimination matters. I worked
from 1997 through 1999 as an associate at the firm of Dienst & Serrins where I managed the firm’s
employment practice, represented plaintiffs in a wide range of employment matters, and served as
lead trial counsel in 3 federal jury trials.
5. I started the Ottinger Firm in 1999. At the Ottinger Firm, I served as lead counsel in
over two hundred employment cases involving a wide range of legal claims, a role in which I
continue to engage. I have handled Fair Labor Standards Act cases since 2008. The Ottinger
Firm, in addition to this case, has handled numerous class actions involving wage and hour claims.
The Ottinger Firm has represented or continues to represent plaintiffs in, among others, the following
class and/or collective actions and putative class and/or collective actions:
DECLARATION OF ROBERT OTTINGER IN SUPPORT OF
PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND AWARDS OF ATTORNEYS’ FEES, COSTS, AND INCENTIVE PAYMENTS
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i. Spencer v. Bargain Land, 10-CV-957.
ii. Mas v. Cumulus Media Inc., 10-CV-01396
iii. Fouathia v. Gurwitch Products, 10-CV-6411
iv. Me Gomez v. Bloomberg Technology, Inc., 10-CV-6412
v. Bardouille v. Goldman Sachs& Cq., 10-CV-4285
vi. Ellis v. Ben’s Asphalt, et al., 30-2009-00329394
vii. Parnell v. Kroll On Track, Inc., 11-CV-0473
viii. Landin v. UBS, 10-CV-711
ix. Mas v. Cumulus Media Partners, 10-CV-1396
x. Martinez v. Forest Laboratories, 10-CV-06032
xi. Orgill v. Ingersoll-Rand Company, 101142-2010
xii. Staley v. Lifetouch Inc., 10-CV-3464
xiii. Dorn v. Eddington Security, Inc., 08-CV-l 0271
xiv. Olivia v. Executive Cellular Phones, Inc., l l-CV-3994
xv. Vosilla v. Novo Nordisk, Inc., l l-CV-3744
xvi. Chisholm v. Sanofi-Aventis U.S. LLC, l l-CV-7758
xvii. McKenzie v. Schulte Roth & Zabel, LLP, l l-CV-3991
xviii. Cruz v. Shiseido Americas, Inc., 11-CV-6622
xix. Doyle v. MapMyFitness, l l-CV-05879
xx. Butt v. Megabus Northeast, LLC, 11-CV-3993
xxi. Gomez v. Gravitas Technology, Inc., 10-CV-6412
xxii. Szu v. TGI Friday’s, Inc., 12-CV-2707
xxiii. Keller v. Axa Equitable Life Insurance Company, 12-CV-4565
xxiv. Kozik v. Hamilton College, 12-CV-1870
xxv. Lebron v. Apple-Metro, Inc., 12-CV-1411
xxvi. Dalton v. Gem Financial Services, Inc., 15-CV-05636
6. Among these cases, The Ottinger Firm has been appointed as class counsel in
Bardouille v, Goldman Sachs & Co., 10-CV-4285; Mas v. Cumulus Media Partners, No. 10-CV-
1396; Landin v. UBS, 10-CV-711; Martinez v, Forest Laboratories, 10-CV-06032; Orgill v
with Outten & Golden LLP); and Lebron v. Apple-Metro, Inc., 12-CV-1411.
7. Attached hereto as Exhibit 1 are true and correct copies of The Ottinger Firm’s time
records for this case.
8. I am requesting for this Court to apply an hourly rate of $550.00 for my services. I have
spent 106.53 hours on this case so far. This rate is reasonable in view of my qualifications and the
supporting evidence submitted herewith.
9. Ashley Pellouchoud was an associate at this firm and has billed 191 hours on this
matter and is billed at the rate of $450 per hour. She has over five years of employment law experience
at some of the leading law firms in the Bay Area such as Outten & Golden. Her practice over the years
focuses exclusively on employee rights in wage & hour and wrongful termination cases. She graduated
from Golden Gate University School of Law in 2012. Her resume is attached as Exhibit 2.
10. Erica Sanders was an associate at this firm and has billed 42 hours on this case at the
rate of $400 per hour. Ms. Sanders is a 2015 graduate of McGill University, Faculty of Law located in
Montreal, Canada. She is a member of the New York bar and has three years of legal experience, one
of which is in employment law obtained at The Ottinger Firm. Her resume is attached as Exhibit 3.
11. Benjamin Weisenberg is a 2011 graduate of Capital University Law School located in
Columbus, Ohio. He has billed 14 hours in this case at the rate of $550 per hour. He is a member of
the California Bar and has over eight years of legal experience and three years of that is in
employment law. He has handled over a dozen wage & hour cases and approximately 100 other
employment cases ranging from wrong termination, severance negotiations, restrictive covenants and
more. His resume is attached as Exhibit 4.
12. Ari Graff is a UCLA Law School graduate with over ten (10) years of employment law
experience. He has handled dozens of wage & hour cases and hundreds of other employment related
cases. He is a member of the New York bar. He billed seven hours at the rate of $550 per hour.
13. Both Daniel Galindo and Nicholas Lunsford are recent graduates of Hastings Law
School in San Francisco. They are both admitted to the California State Bar and have been billed at the
rate of $300 per hour. Mr. Galindo is a current associate at this firm has eight hours of time on this
case and Mr. Lunsford is a former associate who has 13.5 hours billed on this matter. Mr. Galindo’s
resume is attached as Exhibit 5. Mr. Lunsford’s resume is attached as Exhibit 6.
14. In total, The Ottinger Firm has billed 576 hours on this case, which results in a lodestar
of $214,944.50 without the use of any multiplier.
DECLARATION OF ROBERT OTTINGER IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND AWARDS OF
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15. Based on my understanding of their qualifications and the evidence submitted, the
hourly rates used in these calculations are fair, adequate, and reasonable. I am informed and believe
that the breakdown of their time and rates is accurately set forth above.
16. Accordingly, I am informed and believe that Class Counsel’s total lodestar is
$262,144.50. When compared against the $493,333.33 fee request, this results in a modest multiplier
of 1.88.
17. The fee request here is justified because the fees requested are within the market rate
and Class Counsel achieved a substantial recovery for the Class in a risky case while bearing the
substantial burdens of representation on a contingency basis.
18. My co-counsel and I obtained a substantial recovery for the Class in a case fraught with
risk. As discussed in connection with obtaining approval of the Settlement, this case is fraught with
risk respect to both class certification and merits issues. The wage and hour issues here are a
developing area of case law with conflicting authorities (and ever-increasing uncertainty) with respect
to merits issues, and recent class action practice has shown that obtaining class certification is often
quite difficult, especially in cases involving alleged off-the-clock work and meal and rest period
violations. Indeed, to successfully certify a case of this nature, a plaintiff not only has to show that the
case presents predominant common issues, but also can be fairly and efficiently managed on a class-
wide basis. This includes being able to show that affirmative defenses, whether a meal or rest period
that was authorized in writing was denied, are susceptible to common proof and can be fairly and
efficiently managed on a class-wide basis. Given that the majority of Defendant’s liability exposure
arises from these claims (including most of the derivative penalties claims in this case), my co-counsel
and I obtained an extremely favorable result.
19. Attached hereto as Exhibit 7 are true and correct copies of my firm’s costs records for
this case to date showing that we have incurred approximately $17,877.11 in costs. When coupled
with the $6,591.92 in costs incurred by the Law Offices of Louis Benowitz, my co-counsel and I have
incurred total costs of approximately $24,469.03.
20. Further, my co-counsel and I should be compensated undertaking these risks on a pure
contingency basis. Since undertaking representation of Plaintiffs (and the named plaintiffs who came
before them), my co-counsel and I have borne all the costs of litigation without receiving any
compensation to date for the claims in this case. During this time, we will have expended more than
$24,000.00 in costs, and devoted significant time to this litigation. Our efforts have included, among
other things, conferring with Plaintiffs (and previously named plaintiffs who withdrew from being
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DECLARATION OF ROBERT OTTINGER IN SUPPORT OF
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named plaintiffs) to identify and gather information about the claims in this lawsuit, drafting pleadings
and correspondence with government agencies, reviewing policy and payroll documents from
Defendant, interviewing Class Members and obtaining declarations, drafting a detailed mediation
brief, participating in mediation, drafting, finalizing, amending, and obtaining approval of the
Settlement, and addressing post-Settlement issues such as the claims administration process. Given
the considerable potential for adverse outcomes in this case (as discussed in this Motion and the
Preliminary Approval papers), the contingent risk was great. This litigation also took a considerable
amount of time and effort that we could have spent on other cases, albeit hourly cases or lower risk
contingency cases. Indeed, given the resources of Defendant in this case, and the likely difficulties
with prevailing on the vast majority of the claims asserted, this was a risky case for Class Counsel to
pursue. In turn, without our representation and undertaking of this risk, the Class in this case would
not be able to enjoy significant recoveries that the Settlement affords. The quality of our work, and the
efficacy and dedication with which it was performed, should be compensated.
21. Our previous experience in litigating wage and hour class actions also supports the
reasonableness of the fee request, as does the caliber of opposing counsel. Our experience in similar
matters was integral in evaluating the strengths and weaknesses of the case against Defendant and the
reasonableness of the Settlement. Practice in the narrow field of wage and hour litigation, especially in
cases involving meal and rest period claims, requires particular attention to nuances concerning ever-
evolving procedural and substantive issues. This is especially so given recent changes in the legal
landscape surrounding class certification. Indeed, even though California courts have recently been
fairly receptive to granting class certification in wage and hour cases, the U.S. Supreme Court has
gone in the opposite direction, and the California Supreme Court has followed the U.S. Supreme
Court’s lead to a significant extent in view of its decision in Duran v. U.S. Bank Nat’l Assn. (2014) 59
Cal.4th 1 by placing a heightened emphasis on manageability considerations even in cases that present
predominant common questions. Our previous experience in wage and hour class action cases was
integral in being able to resolve this case on favorable terms for the Class because that experience
enabled us to pinpoint issues that likely encouraged Defendant to resolve this case for fair
compensation on a class-wide basis instead of proceeding to class certification and beyond. Because it
is reasonable to compensate us commensurate with their skill, reputation, and experience, the
requested fee award warrants this Court’s final approval.
22. The Incentive Awards of $10,000.00 for each of the Plaintiffs are entirely reasonable
given their efforts in this case and the risks they undertook on behalf of the Class. Here, Plaintiffs
DECLARATION OF ROBERT OTTINGER IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT AND AWARDS OF
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advanced the interests of the Class by, among other things, speaking with counsel in person and over
the telephone, gathering documents, assisting counsel in identifying potential claims and in preparing
for the mediation, and risking being required to pay Defendant’s costs if this action had been
unsuccessful. Moreover, Plaintiffs took the personal risks of potentially facing intrusive discovery and
disclosure to future employers that they sued a former employer, making their futures uncertain.
Further, Plaintiffs came forward as class representatives to allow this case to proceed after the
previous named plaintiffs withdrew. Finally, Plaintiffs are agreeing to a much broader release of
claims than other Class Members. Given these considerations, the modest Incentive Awards to
Plaintiffs are appropriate and justified as part of the Settlement.
I declare under the penalty of perjury of the laws of the State of California that the foregoing is
true and correct.
Executed on February 19, 2019 at San Francisco, California.
___________________________ ROBERT W. OTTINGER THE OTTINGER FIRM, P.C. [email protected] 535 Mission Street, 14th Floor San Francisco, CA 94105Declarant
EXHIBIT 1
Description Quantity Unit Price Amount
[W] SoFi [11] - 07/27/2017 - Case Assessment, Development and Administration /Robert Ottinger: Numerous calls with various witnesses and potential classmembers.
3.50 $550.00 $1,925.00
[W] SoFi [11] - 07/28/2017 - Case Assessment, Development and Administration /Robert Ottinger: Further calls with witnesses
1.40 $550.00 $770.00
[W] SoFi [11] - 08/02/2017 - Case Assessment, Development and Administration /Kathryn Daly: Case Opener
0.27 $150.00 $40.50
[W] SoFi [11] - 08/02/2017 - Case Assessment, Development and Administration /Kathryn Daly: New Clients
0.12 $150.00 $18.00
[W] SoFi [11] - 08/03/2017 - Case Assessment, Development and Administration /Kathryn Daly: Opt In Notes
0.85 $150.00 $127.50
[W] SoFi [11] - 08/03/2017 - Communcation (in firm) / Robert Ottinger: CAlls withpotential opt ins and calls in firm re same.
0.70 $550.00 $385.00
[W] SoFi [11] - 08/04/2017 - Case Assessment, Development and Administration /Kathryn Daly: Case Opener
0.20 $150.00 $30.00
[W] SoFi [11] - 08/04/2017 - Communication (other external) / Kathryn Daly:Potential Opt in Kathy Snyder
0.03 $150.00 $4.50
[W] SoFi [11] - 08/07/2017 - Draft/Revise / Robert Ottinger: Begin draftingcomplaint
0.40 $550.00 $220.00
[W] SoFi [11] - 08/08/2017 - Case Assessment, Development and Administration /Kathryn Daly: Case Manager
From The Ottinger Firm, PC.401 Park Avenue South 10th Floor New York, NY 10016
Phone: 212-571-2000
Invoice For @SoFiInvoice ID 2822
Issue Date 02/19/2019
Due Date 02/19/2019 (upon receipt)
Page 1 of 52
[W] SoFi [11] - 08/10/2017 - Communication (other external) / Ari Graff:conferences with R Ottinger and L Benowitz re Class complaint; research andreview re same
0.81 $600.00 $486.00
[W] SoFi [11] - 08/10/2017 - Communcation (in firm) / Robert Ottinger: CAlls withAG and local counsel
0.90 $550.00 $495.00
[W] SoFi [11] - 08/11/2017 - Communcation (in firm) / Ari Graff: w D Strellman reComplaint
[W] SoFi [11] - 08/14/2017 - Draft/Revise / Daniel Strellman: Drafting complaint,cover sheet, and summons. Filing case via OneLegal. Calling OneLegal re filing.
2.49 $150.00 $373.50
[W] SoFi [11] - 08/14/2017 - Communcation (in firm) / Ari Graff: w D Strellman LBenowitz and R Ottinger re class complaint; filing; press
1.92 $600.00 $1,152.00
[W] SoFi [11] - 08/14/2017 - Analysis/Strategy / Robert Ottinger: Calls from formerSoFi employees regarding their experiences. Calls with media covering the filing ofthe case.
5.00 $550.00 $2,750.00
[W] SoFi [11] - 08/14/2017 - Analysis/Strategy / Robert Ottinger: Calls with localcounsel and staff re damages.
1.30 $550.00 $715.00
[W] SoFi [11] - 08/15/2017 - Document/File Managment / Daniel Strellman:Checking for summons returned.
0.18 $150.00 $27.00
[W] SoFi [11] - 08/15/2017 - Communcation (in firm) / Ari Graff: w R Ottinger readditional witnesses and potential amended complaint; re anonymous board letterand review same; conferences and exchange drafts w R Ottinger recorrespondence with Sofi; conference with L benowitz re same
3.21 $600.00 $1,926.00
[W] SoFi [11] - 08/15/2017 - Analysis/Strategy / Robert Ottinger: Calls with SoFiemployees. Fact gathering about wage practices.
[W] SoFi [11] - 08/17/2017 - Case Assessment, Development and Administration /Daniel Strellman: Checking court docket. Adding case dates and deadlines to casecalendar. Adding tasks. Adding hearing to attorney calendar. Saving Notice ofConference. Preparing documents for service and serving D. Calling potential opt-in back. Performing TLOxp and social media searches on SoFi CEO.
3.17 $150.00 $475.50
[W] SoFi [11] - 08/17/2017 - Research / Andrew Ottinger: Performing social mediaand general internet searches on M. Cagney CEO, N. Fanlo, M. Tanebaum.
4.50 $250.00 $1,125.00
Page 2 of 52
[W] SoFi [11] - 08/17/2017 - Analysis/Strategy / Robert Ottinger: Reviewing work byDaniel and calls with opt ins.
2.10 $550.00 $1,155.00
[W] SoFi [11] - 08/18/2017 - Document/File Managment / Daniel Strellman: Savingclient document to SP. Adding disc. tasks to case.
0.27 $150.00 $40.50
[W] SoFi [11] - 08/18/2017 - Research / Andrew Ottinger: Reporting on findingsfrom social media and internet searches to attorney.
0.08 $250.00 $20.00
[W] SoFi [11] - 08/21/2017 - Admin / Daniel Strellman: Expensing Complaint filing.Expensing service
0.14 $150.00 $21.00
[W] SoFi [11] - 08/22/2017 - Case Assessment, Development and Administration /Kathryn Daly: New Plaintiffs
0.08 $150.00 $12.00
[W] SoFi [11] - 08/22/2017 - Communcation (in firm) / Daniel Strellman:Communication w/ R. Ottinger and K. Daly re new plaintiffs. Reviewing mail forcase. Conducting a search for prior SoFi cases online, on SF and nearby courtwebsites, Boston, and Austin. Saving and filing proof of service.
1.27 $150.00 $190.50
[W] SoFi [11] - 08/22/2017 - Pleadings / Ari Graff: and research re SoFi litigationhistory; conferences w D Strellman and K Daly re same
1.31 $600.00 $786.00
[W] SoFi [11] - 08/22/2017 - Case Assessment, Development and Administration /Robert Ottinger: Calls with DS and KD re new plaintiffs and calls with AG strategyand next steps.
2.40 $550.00 $1,320.00
[W] SoFi [11] - 08/24/2017 - Case Assessment, Development and Administration /Kathryn Daly: Calling Kathryn Snyder
0.06 $150.00 $9.00
[W] SoFi [11] - 08/28/2017 - Case Assessment, Development and Administration /Kathryn Daly: Potential Opt-In
0.17 $150.00 $25.50
[W] SoFi [11] - 08/28/2017 - Review and Analyze / Benjamin Weisenberg: ReviewPleadings & possible poaching issue.
0.31 $550.00 $170.50
[W] SoFi [11] - 08/28/2017 - Admin / Daniel Strellman: Saving new retainer. AddingA. Katsoulis contact info from retainer to case.
[W] SoFi [11] - 08/29/2017 - Case Assessment, Development and Administration /Kathryn Daly: Case Management New Representatives
0.23 $150.00 $34.50
[W] SoFi [11] - 08/29/2017 - Communication (with client) / Daniel Strellman: Emailfrom R. Mosso.
0.08 $150.00 $12.00
Page 3 of 52
[W] SoFi [11] - 08/30/2017 - Communcation (in firm) / Benjamin Weisenberg:Planning session, and discussion of Amended Complaints. Discuss additionalcomplaints to come.
0.59 $550.00 $324.50
[W] SoFi [11] - 08/30/2017 - Case Assessment, Development and Administration /Robert Ottinger: Calls re Planning with BW- amending complaint etc.
[W] SoFi [11] - 08/31/2017 - Communcation (in firm) / Benjamin Weisenberg:Discuss re: amending complaints. Call possible opt ins.
0.75 $550.00 $412.50
[W] SoFi [11] - 08/31/2017 - Case Assessment, Development and Administration /Kathryn Daly: New Reps Information
0.38 $150.00 $57.00
[W] SoFi [11] - 09/01/2017 - Draft/Revise / Daniel Strellman: Checking PAGAsituation. Meeting with R. Ottinger and B. Weisenberg. Email to Louis. DraftingPAGA letter and online submittance. Printing and mailing.
0.59 $150.00 $88.50
[W] SoFi [11] - 09/01/2017 - Communcation (in firm) / Benjamin Weisenberg:Discussion w/ RO/DS re: amending complaints and PAGA.
1.20 $550.00 $660.00
[W] SoFi [11] - 09/01/2017 - Case Assessment, Development and Administration /Kathryn Daly: NY Times and Yulia
0.08 $150.00 $12.00
[W] SoFi [11] - 09/01/2017 - Communcation (in firm) / Robert Ottinger: Meetingswith BW, DS re amending complaitn, PAGA, calls with co counsel re same.
1.40 $550.00 $770.00
[W] SoFi [11] - 09/05/2017 - Communcation (in firm) / Benjamin Weisenberg:Phone call to discuss strategy.
0.19 $550.00 $104.50
[W] SoFi [11] - 09/06/2017 - Case Assessment, Development and Administration /Kathryn Daly: Anjali Notes
1.11 $150.00 $166.50
[W] SoFi [11] - 09/06/2017 - Communication (with client) / Daniel Strellman:Scheduling calls with J. Baughman & C. Smith.
[W] SoFi [11] - 09/13/2017 - Case Assessment, Development and Administration /Kathryn Daly: Tina Cane
0.16 $150.00 $24.00
[W] SoFi [11] - 09/14/2017 - Draft/Revise / Daniel Strellman: Researching LWDAPaga requirements and instructions. Drafting LWDA submittance letters. E-filingwith the LWDA online. Going to USPS to send to D via certified mail. FedExingcheck to LWDA. Saving drafts and scans of said documents to SP.
[W] SoFi [11] - 09/16/2017 - Communication (with client) / Robert Ottinger: CallAngie K re concerns about case. Call with Bri Pilling about implied threats fromCagney and his wife June. Bri wants to re-join the case. Case management -setting tasks.
[W] SoFi [11] - 09/20/2017 - Case Assessment, Development and Administration /Kathryn Daly: Marketing: Sex Scandal Parallels
0.89 $150.00 $133.50
[W] SoFi [11] - 09/20/2017 - Case Assessment, Development and Administration /Kathryn Daly: Contact list w/ Anjali
0.40 $150.00 $60.00
[W] SoFi [11] - 09/21/2017 - Case Assessment, Development and Administration /Kathryn Daly: Trina Bagley
0.15 $150.00 $22.50
[W] SoFi [11] - 09/22/2017 - Case Assessment, Development and Administration /Daniel Strellman: Discussing discovery forms needed for written discoverydemands with K. Daly
[W] SoFi [11] - 10/25/2017 - Document Production / Seth Persaud: Checking overRFP'S and ROG's
0.61 $0.00 $0.00
[W] SoFi [11] - 10/25/2017 - Document Production / Seth Persaud: Looking intoClient Case files on Share point for Zamora, Jackson and Huskey
0.51 $0.00 $0.00
[W] SoFi [11] - 10/27/2017 - Case Assessment, Development and Administration /Seth Persaud: Completing Zamora SoFi Discovery Demands and sending to Benfor review
1.04 $0.00 $0.00
[W] SoFi [11] - 10/30/2017 - Case Assessment, Development and Administration /Kathryn Daly: New retainer
0.16 $150.00 $24.00
[W] SoFi [11] - 10/30/2017 - Communication (other external) / Kathryn Daly:Amanda Vera
[W] SoFi [11] - 10/31/2017 - Case Assessment, Development and Administration /Kathryn Daly: Marchman, Shelton
0.37 $150.00 $55.50
[W] SoFi [11] - 11/01/2017 - Research / Daniel Strellman: Researching dismissal ofnamed plaintiff from a class action and getting court permission to file an amendedcomplaint. Email to Louis. More research on the motion for leave to amend.
0.59 $150.00 $88.50
[W] SoFi [11] - 11/01/2017 - Draft/Revise / Daniel Strellman: Drafting B.Weisenberg Pro Hac Application. Downloading and saving Order. Running OCR onorder. Updating case calendar to reflect moved case management conference.Registering with mandatory e-filing and e-service company; completed. CallingDept. 305 to reserve a court date.
2.98 $150.00 $447.00
[W] SoFi [11] - 11/02/2017 - Draft/Revise / Daniel Strellman: Drafting motion forleave to file amended complaint
[W] SoFi [11] - 11/03/2017 - Communication (with opposition/outside counsel) /Benjamin Weisenberg: Discuss and draft email re: extension w/ KD.
0.25 $550.00 $137.50
[W] SoFi [11] - 11/03/2017 - Communcation (in firm) / Robert Ottinger: Discussingdiscovery w/BW, ES & DS
0.40 $550.00 $220.00
[W] SoFi [11] - 11/06/2017 - Case Assessment, Development and Administration /Daniel Strellman: Checking that POS was filed in a timely manner. It was.
0.06 $150.00 $9.00
[W] SoFi [11] - 11/08/2017 - Communication (with opposition/outside counsel) /Erica Sanders: We spoke about the amended complaint.
0.25 $450.00 $112.50
[W] SoFi [11] - 11/08/2017 - Communication (with opposition/outside counsel) /Robert Ottinger: Call with D counsel re amending complaint and discovery. Prep forsame.
0.50 $550.00 $275.00
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[W] SoFi [11] - 11/09/2017 - Case Assessment, Development and Administration /Daniel Strellman: Email to K. Daly and A. Ottinger re class representatives. Findingdates for LB. Checking off tasks.
0.67 $150.00 $100.50
[W] SoFi [11] - 11/09/2017 - Communcation (in firm) / Daniel Strellman: Meetingwith R. Ottinger and E. Sanders. Email to LB. Updating tasks. Calling court rehearing dates staying or being postponed.
1.08 $150.00 $162.00
[W] SoFi [11] - 11/09/2017 - Case Assessment, Development and Administration /Kathryn Daly: List of Best Reps
0.42 $150.00 $63.00
[W] SoFi [11] - 11/09/2017 - Communcation (in firm) / Daniel Strellman: Call with E.Sanders re drafting the amended complaint.
0.11 $150.00 $16.50
[W] SoFi [11] - 11/09/2017 - Review and Analyze / Anjie Koul: ReviewedDefendant's opposition to Plaintiff's motion to quash subpoena
0.25 $550.00 $137.50
[W] SoFi [11] - 11/09/2017 - Communcation (in firm) / Robert Ottinger: Meetingw/ES & DS reg email to co-counsel LB and updating tasks, etc.
1.00 $550.00 $550.00
[W] SoFi [11] - 11/10/2017 - Communcation (in firm) / Daniel Strellman: In firmmeeting with K. Daly re named plaintiffs. Email to opposing counsel re JCMS beingpushed back.
0.55 $150.00 $82.50
[W] SoFi [11] - 11/10/2017 - Communcation (in firm) / Daniel Strellman: Attemptingto call San Francisco Superior Court.
0.23 $150.00 $34.50
[W] SoFi [11] - 11/10/2017 - General / Anjie Koul: Spoke with KD re SOFI casestatuses and discovery (Brandon Charles and Yulia Zamora)
1.00 $550.00 $550.00
[W] SoFi [11] - 11/10/2017 - Pleadings / Erica Sanders: I am drafting the ammcomplaint
2.18 $450.00 $981.00
[W] SoFi [11] - 11/13/2017 - Draft/Revise / Daniel Strellman: Preparing motion forleave to amend. Drafting proof of service, proposed order, and declaration of R.Ottinger for the motion.
1.60 $150.00 $240.00
[W] SoFi [11] - 11/13/2017 - Draft/Revise / Daniel Strellman: Meeting re draftingmotion.
0.22 $150.00 $33.00
[W] SoFi [11] - 11/13/2017 - Pleadings / Erica Sanders: I am drafting a memo re theamended complaint.
[W] SoFi [11] - 11/14/2017 - Draft/Revise / Daniel Strellman: Drafting motion forleave to amend documents
2.03 $150.00 $304.50
[W] SoFi [11] - 11/14/2017 - Pleadings / Erica Sanders: I am drafting the memo insupport of amendment. I am also calling the new named reps.
3.62 $450.00 $1,629.00
Page 12 of 52
[W] SoFi [11] - 11/14/2017 - Communcation (in firm) / Daniel Strellman: Discussingmotion with E. Sanders.
0.10 $150.00 $15.00
[W] SoFi [11] - 11/14/2017 - Case Assessment, Development and Administration /Daniel Strellman: Saving court order and adding requisite dates and tasks to case.
0.27 $150.00 $40.50
[W] SoFi [11] - 11/14/2017 - Communcation (in firm) / Daniel Strellman: Discussionwith E. Sanders
0.10 $150.00 $15.00
[W] SoFi [11] - 11/15/2017 - Research / Erica Sanders: I am researching contactwith cert class
2.28 $450.00 $1,026.00
[W] SoFi [11] - 11/15/2017 - Communication (with opposition/outside counsel) /Daniel Strellman: Email re hearing scheduling to opposing counsel. Updating casecalendar.
0.10 $150.00 $15.00
[W] SoFi [11] - 11/17/2017 - Draft/Revise / Daniel Strellman: Adding to JCMS. 0.79 $150.00 $118.50
[W] SoFi [11] - 11/17/2017 - Project Management / Erica Sanders: I am drafting theCMC Statement. I am also reading the pleadings to catch upon the case.
2.50 $450.00 $1,125.00
[W] SoFi [11] - 11/17/2017 - Pleadings / Erica Sanders: I am amending theamended complaint and notice to remove PAGA
0.21 $450.00 $94.50
[W] SoFi [11] - 11/20/2017 - Communcation (in firm) / Daniel Strellman: Email to R.Ottinger to get approval to file JCMS.
0.28 $150.00 $42.00
[W] SoFi [11] - 11/20/2017 - Other / Erica Sanders: I am reviewing the casemanagement statement
0.70 $450.00 $315.00
[W] SoFi [11] - 11/20/2017 - Communcation (in firm) / Robert Ottinger: Email w/DSreg approval for file JCMS.
0.24 $550.00 $132.00
[W] SoFi [11] - 11/21/2017 - Other / Erica Sanders: I am reinserting paga claimsinto the amm complaint.
0.72 $450.00 $324.00
[W] SoFi [11] - 11/22/2017 - Draft/Revise / Jose Caceres: Proofreadingmemorandum for Erica
[W] SoFi [11] - 11/22/2017 - Other Written Motions and Submissions / EricaSanders: Researching injunctions and conference calling.
1.50 $450.00 $675.00
[W] SoFi [11] - 11/22/2017 - Communcation (in firm) / Erica Sanders: Discussinginjunctions and doing research. Speaking to ethics lawyers.
1.50 $450.00 $675.00
[W] SoFi [11] - 11/26/2017 - Review and Analyze / Benjamin Weisenberg: review Dcounsel's response to motion to quash
0.29 $550.00 $159.50
Page 13 of 52
[W] SoFi [11] - 11/26/2017 - Review and Analyze / Robert Ottinger: review d'sresponse motion to quash
0.30 $550.00 $165.00
[W] SoFi [11] - 11/27/2017 - Manage data/files / Daniel Strellman: Looking up caseonline. Reviewing docket. Downloading, saving, and uploading order reassigningcase.
0.32 $150.00 $48.00
[W] SoFi [11] - 11/27/2017 - Pleadings / Erica Sanders: I am perping for CMConference tomorrow.
1.47 $450.00 $661.50
[W] SoFi [11] - 11/27/2017 - Case Assessment, Development and Administration /Daniel Strellman: Checking for JCMS for E. Sanders. Call from same. Checking e-service settings. Saving documents from D counsel emails.
0.35 $150.00 $52.50
[W] SoFi [11] - 11/27/2017 - Pleadings / Erica Sanders: Call with Ed McIntyre 0.87 $450.00 $391.50
[W] SoFi [11] - 11/27/2017 - Research / Daniel Strellman: Checking the Rutterguide for parts to motion for leave to amend.
0.17 $150.00 $25.50
[W] SoFi [11] - 11/27/2017 - Review and Analyze / Daniel Strellman: Reviewing andrevising the motion for leave to amend and amended complaint. Doing allnecessary corrections and additions. Calls with E. Sanders re the filing. Filing themotion. Expensing the filing.
5.18 $150.00 $777.00
[W] SoFi [11] - 11/27/2017 - Pleadings / Erica Sanders: I am discussing ammcomplaint with Daniel and Louis.
0.75 $450.00 $337.50
[W] SoFi [11] - 11/27/2017 - Research / Erica Sanders: I am researching the dutyof confidentiality.
0.75 $450.00 $337.50
[W] SoFi [11] - 11/27/2017 - Communcation (in firm) / Robert Ottinger: Review case 0.50 $550.00 $275.00
[W] SoFi [11] - 11/28/2017 - Communcation (in firm) / Benjamin Weisenberg:Discuss new claims w/ RO prior to CC hearing
0.66 $550.00 $363.00
[W] SoFi [11] - 11/28/2017 - Case Assessment, Development and Administration /Daniel Strellman: In-firm communication with R. Ottinger and E. Sanders. Calls tocourt clerk re e-filing. Checking case docket. Call to File&ServeXpress; live chat forhelp instead.
[W] SoFi [11] - 11/28/2017 - Case Assessment, Development and Administration /Daniel Strellman: Call from R. Ottinger re hearing. Saving new dates anddeadlines. Creating detailed tasks in Basecamp. Researching and saving model forstipulation and proposed order to amend. Adding individual, local, and state rulesto basecamp.
0.73 $150.00 $109.50
[W] SoFi [11] - 11/28/2017 - Court Mandated Conferences / Robert Ottinger: Prepfor and attend CMC.
1.60 $550.00 $880.00
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[W] SoFi [11] - 11/29/2017 - Case Assessment, Development and Administration /Daniel Strellman: Saving case management order and ensuring that all dates anddeadlines are added to the case calendar.
0.23 $150.00 $34.50
[W] SoFi [11] - 11/29/2017 - General / Erica Sanders: sofi stipulation and discovery.I am coordinating discovery with Daniel.
1.35 $450.00 $607.50
[W] SoFi [11] - 11/29/2017 - Draft/Revise / Daniel Strellman: Discussion with E.Sanders. Drafting discovery requests: form rogs, PMK depo notice, requests forproduction, and working on special rogs.
[W] SoFi [11] - 12/01/2017 - Written Discovery / Daniel Strellman: Servingdiscovery on D via File&Serve. Drafting proof of service for File&Serve service.Checking relevant local and indv. rules re e-service in this situation. Drafting emailto opposing counsel too.
0.61 $150.00 $91.50
[W] SoFi [11] - 12/01/2017 - General / Erica Sanders: Stipulation with opp counsel 0.20 $450.00 $90.00
[W] SoFi [11] - 12/04/2017 - Case Assessment, Development and Administration /Kathryn Daly: ES question
0.09 $150.00 $13.50
[W] SoFi [11] - 12/04/2017 - Research / Daniel Strellman: Re ABA law schoolrequirement for Pro Hac application.
0.10 $150.00 $15.00
[W] SoFi [11] - 12/04/2017 - Case Assessment, Development and Administration /Daniel Strellman: Affixing amended complaint to stipulation. Filing stipulation.Calling clerk to take motion hearing off the calendar. Discussions with E. Sanders.
0.95 $150.00 $142.50
[W] SoFi [11] - 12/04/2017 - Case Assessment, Development and Administration /Daniel Strellman: Discussion with E. Sanders.
[W] SoFi [11] - 12/08/2017 - Case Assessment, Development and Administration /Daniel Strellman: Assessing rejection reasoning. Checking individual and localrules. Fixing stipulation and re-filing.
0.57 $150.00 $85.50
[W] SoFi [11] - 12/11/2017 - Pleadings / Erica Sanders: new PAGA letter 0.85 $450.00 $382.50
[W] SoFi [11] - 12/11/2017 - Draft/Revise / Jose Caceres: Proofreading letter toSoFi
0.17 $250.00 $42.50
[W] SoFi [11] - 12/11/2017 - Admin / Daniel Strellman: Reviewing emails fromopposing counsel. Email to Y. Zamora. Meeting. Email to R. Ottinger. Drafting letterto opposing counsel.
1.27 $150.00 $190.50
[W] SoFi [11] - 12/11/2017 - Draft/Revise / Robert Ottinger: Review draft letter toopp counsel w/DS & JC
0.83 $550.00 $456.50
[W] SoFi [11] - 12/12/2017 - Communication (with client) / Erica Sanders: Speakingto Betty Miles about case
[W] SoFi [11] - 12/12/2017 - Communication (with client) / Erica Sanders:Discussing opp counsel email with Louis and amending PGA letter.
0.31 $450.00 $139.50
Page 16 of 52
[W] SoFi [11] - 12/12/2017 - Communcation (in firm) / Daniel Strellman:Summarizing our discovery requests and sending it to R. Ottinger. Saving letterfrom D.
0.57 $150.00 $85.50
[W] SoFi [11] - 12/12/2017 - General / Erica Sanders: Paga letter 0.59 $450.00 $265.50
[W] SoFi [11] - 12/12/2017 - Document/File Managment / Jose Caceres: CombiningPDF's for ES
[W] SoFi [11] - 12/12/2017 - Communcation (in firm) / Robert Ottinger: Reviewingemails and communication
0.50 $550.00 $275.00
[W] SoFi [11] - 12/13/2017 - Communcation (in firm) / Daniel Strellman: Draftingemail to send to opposing counsel. Checking special interrogatories and updatinglist to include information.
0.68 $150.00 $102.00
[W] SoFi [11] - 12/13/2017 - Other / Daniel Strellman: Preparing amended PAGAnotice. Meeting with E. Sanders.
0.42 $150.00 $63.00
[W] SoFi [11] - 12/14/2017 - Communication (with opposition/outside counsel) /Daniel Strellman: Email to R. Ottinger. Email to opposing counsel.
0.12 $150.00 $18.00
[W] SoFi [11] - 12/14/2017 - Case Assessment, Development and Administration /Kathryn Daly: Prep for Pillings
[W] SoFi [11] - 12/14/2017 - General / Erica Sanders: Entering in call notes fromTuesday call with new class rep Betty Miles
0.13 $450.00 $58.50
[W] SoFi [11] - 12/14/2017 - Communcation (in firm) / Robert Ottinger: email w/DS 0.10 $550.00 $55.00
[W] SoFi [11] - 12/15/2017 - General / Erica Sanders: I am reviewing email fromopp counsel and telling RO my thoughts
0.71 $450.00 $319.50
[W] SoFi [11] - 12/15/2017 - General / Robert Ottinger: reviewing email from oppcounsel
0.48 $550.00 $264.00
[W] SoFi [11] - 12/18/2017 - Communcation (in firm) / Erica Sanders: Meeting withLouis and RO, emailing opposing counsel, contacting mediator Rotman to obtainhis dates of availability.
0.67 $450.00 $301.50
[W] SoFi [11] - 12/18/2017 - Communcation (in firm) / Daniel Strellman: Meetingwith R. Ottinger and E. Sanders.
0.25 $150.00 $37.50
Page 17 of 52
[W] SoFi [11] - 12/18/2017 - Communcation (in firm) / Robert Ottinger: Meetingw/ES, DK & co counsel; email opp counsel, contact Rotman to for dates ofmediation
0.69 $550.00 $379.50
[W] SoFi [11] - 12/19/2017 - Document/File Managment / Daniel Strellman: Savingemails to case file. Updating case information from order.
0.30 $150.00 $45.00
[W] SoFi [11] - 12/19/2017 - Case Assessment, Development and Administration /Kathryn Daly: DS Email
0.08 $150.00 $12.00
[W] SoFi [11] - 12/20/2017 - Communcation (in firm) / Erica Sanders: AmendedPaga letter
0.12 $450.00 $54.00
[W] SoFi [11] - 12/20/2017 - Review and Analyze / Jose Caceres: Proofreading 0.17 $250.00 $42.50
[W] SoFi [11] - 12/20/2017 - Document/File Managment / Jose Caceres: Mergingpdfs to file
[W] SoFi [11] - 12/21/2017 - Communcation (in firm) / Benjamin Weisenberg: Teamdiscussion.
0.58 $550.00 $319.00
[W] SoFi [11] - 12/21/2017 - Communcation (in firm) / Robert Ottinger: TeamDiscuss
1.00 $550.00 $550.00
[W] SoFi [11] - 12/22/2017 - Case Assessment, Development and Administration /Daniel Strellman: Case management (i.e. saving court-returned documents. Addingcase dates, deadlines, and tasks)
0.01 $150.00 $1.50
Page 18 of 52
[W] SoFi [11] - 12/22/2017 - Manage data/files / Jose Caceres: SoFi Call List 1.61 $250.00 $402.50
[W] SoFi [11] - 12/22/2017 - Communication (with client) / Jose Caceres 1.83 $250.00 $457.50
[W] SoFi [11] - 12/22/2017 - Case Assessment, Development and Administration /Kathryn Daly: Facebook update
0.25 $150.00 $37.50
[W] SoFi [11] - 12/22/2017 - Document/File Managment / Jose Caceres: Printingprevious notes for clients I left voicemails for to be prepared for their return calls
0.39 $250.00 $97.50
[W] SoFi [11] - 12/26/2017 - Communication (other external) / Daniel Strellman:Email to Rotman mediation office.
0.13 $150.00 $19.50
[W] SoFi [11] - 12/26/2017 - Communcation (in firm) / Benjamin Weisenberg: Teammeeting re: SoFi Class Action & Call list.
0.36 $550.00 $198.00
[W] SoFi [11] - 12/26/2017 - Communcation (in firm) / Kathryn Daly: Fran.Answering her Intake Question
0.25 $150.00 $37.50
[W] SoFi [11] - 12/26/2017 - Communcation (in firm) / Jose Caceres 0.13 $250.00 $32.50
[W] SoFi [11] - 12/27/2017 - Document Production / Jose Caceres: Tree charttemplate for SoFi call project
0.37 $250.00 $92.50
[W] SoFi [11] - 12/27/2017 - Research / Jose Caceres: Reading through thecomplaints, declarations, NY times article and filling in tree chart w/ job titles andemployees. *should have taken me less than 45 minutes, shouldn't have been sothorough.
1.67 $250.00 $417.50
[W] SoFi [11] - 12/27/2017 - Document/File Managment / Daniel Strellman: Savingcorrespondence. Reviewing emails. Adding task to case. Saving objectionsreceived via e-service.
0.51 $150.00 $76.50
[W] SoFi [11] - 12/27/2017 - Communication (with client) / Robert Ottinger: Call withSoFi people for background
0.74 $550.00 $407.00
[W] SoFi [11] - 12/27/2017 - Communication (other external) / Jose Caceres:Phone call with Brandon Charles and Robert regarding SoFi structure, and gettinga bigger picture perspective of the company's way of operating.
0.67 $250.00 $167.50
[W] SoFi [11] - 12/27/2017 - Communcation (in firm) / Benjamin Weisenberg:Discussion w/ RO. Notes to Sp. Email Felicia.
0.69 $550.00 $379.50
[W] SoFi [11] - 12/28/2017 - Case Assessment, Development and Administration /Daniel Strellman: Adjusting case calendar
0.08 $150.00 $12.00
Page 19 of 52
[W] SoFi [11] - 01/02/2018 - Communication (with client) / Kathryn Daly: AnsweringPhone Call w/Robin Mosso. Robin Called Following Up on Jose's Phone Call.
0.10 $150.00 $15.00
[W] SoFi [11] - 01/03/2018 - Other / Erica Sanders: Discussing discovery withopposing counsel. Ben on the line as well.
[W] SoFi [11] - 01/03/2018 - Communication (with opposition/outside counsel) /Daniel Strellman: Sending email to R. Ottinger with D. Rotman mediation schedule.Email to mediator's office asking about May dates available. Preparing email toopposing counsel with the mediation availability.
0.20 $150.00 $30.00
[W] SoFi [11] - 01/03/2018 - Other / Erica Sanders: Inserting SOFI call notes intonotebook and discussing call with RO and Ben. Setting up call with Louis tomorrow.
0.28 $450.00 $126.00
[W] SoFi [11] - 01/03/2018 - Communcation (in firm) / Robert Ottinger: Discussingcall with ES and BW; working with ES to help her up call with co counsel LB
0.29 $550.00 $159.50
[W] SoFi [11] - 01/04/2018 - Admin / Jose Caceres: Scheduling phone call withLouis for BW, Es, and RO
0.12 $250.00 $30.00
[W] SoFi [11] - 01/04/2018 - Communication (with opposition/outside counsel) /Daniel Strellman: Email to opposing counsel. Forwarding mediation datesinformation internally. Adding task to Basecamp to check Rotman's availability formediation again on February 1 and to email D for electronic versions of the rogsthey claim to have sent to us.
0.13 $150.00 $19.50
[W] SoFi [11] - 01/04/2018 - Admin / Jose Caceres: Sending out meeting invites 0.12 $250.00 $30.00
[W] SoFi [11] - 01/04/2018 - Review and Analyze / Jose Caceres: Double checkingthat all time and pay entries were inputted (since I took over mid-way, want tomake sure nothing was missed). I noticed that Seth hadn't put 8 hours for sickdays, vacation days and holidays so I went through all time sheets to correct this.
1.17 $250.00 $292.50
[W] SoFi [11] - 01/04/2018 - Communication (with opposition/outside counsel) /Daniel Strellman: Meeting with E. Sanders re SoFi mediation dates. Checkingemails re same. Further messages with E. Sanders.
0.28 $150.00 $42.00
[W] SoFi [11] - 01/04/2018 - Communcation (in firm) / Kathryn Daly: AnsweringRO's Chat; Looking up "Hollee Landreth"
0.27 $150.00 $40.50
[W] SoFi [11] - 01/04/2018 - Communcation (in firm) / Erica Sanders: Call with ROand Ben about paralegal management to make sure chain of command is in placeespecially re emails to opposing counsel. Then spoke to Daniel separately toexplain issues. Strategized to find solution.
0.38 $450.00 $171.00
[W] SoFi [11] - 01/04/2018 - Communcation (in firm) / Benjamin Weisenberg: Teammeeting w/ ES & LB re: LB's appearance and taking over point.
0.18 $550.00 $99.00
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[W] SoFi [11] - 01/04/2018 - General / Jose Caceres: Adding tentative meeting withMs. Reid to ES' and BW's schedule on google calendar and basecamp.
0.12 $250.00 $30.00
[W] SoFi [11] - 01/04/2018 - Communcation (in firm) / Robert Ottinger: call w/ES &BW
0.35 $550.00 $192.50
[W] SoFi [11] - 01/05/2018 - Communcation (in firm) / Benjamin Weisenberg: Teammeeting.
0.18 $550.00 $99.00
[W] SoFi [11] - 01/05/2018 - General / Robert Ottinger: Conf call with local counsel. 0.80 $550.00 $440.00
[W] SoFi [11] - 01/08/2018 - Document/File Managment / Daniel Strellman: Savingdocument served on us to SP. Saving important correspondence from D to case.
0.13 $150.00 $19.50
[W] SoFi [11] - 01/08/2018 - Document/File Managment / Jose Caceres: Uploadingorganizational structure and proficiency excel sheet sent in by Mr. Charles to SP.
0.07 $250.00 $17.50
[W] SoFi [11] - 01/08/2018 - Communcation (in firm) / Erica Sanders: ReviewingFelicia's 3 page email about discovery. Summarizing email for RO and Ben.
0.23 $450.00 $103.50
[W] SoFi [11] - 01/08/2018 - Communcation (in firm) / Daniel Strellman: Meetingwith E. Sanders re SoFi email from D counsel. Sending photographs of the certifiedmailing of the PAGA letter to myself. Reviewing discovery letter from D; saving thesame to SP. Tracking down evidence of certified mailing of first PAGA Letter.Searching for the tracking number on USPS.com. Saving finding to SP andnotifying E. Sanders.
0.69 $150.00 $103.50
[W] SoFi [11] - 01/09/2018 - Admin / Jose Caceres: Sending meeting invites to ES,RO, Bw and Louis.
0.05 $250.00 $12.50
[W] SoFi [11] - 01/09/2018 - Communcation (in firm) / Daniel Strellman: Messageswith K. Daly re declarations from named plaintiffs. Adding task to case.
0.07 $150.00 $10.50
[W] SoFi [11] - 01/09/2018 - Analysis/Strategy / Robert Ottinger: conf call with localcounsel re discovery for mediation
0.11 $550.00 $60.50
[W] SoFi [11] - 01/10/2018 - Communication (with opposition/outside counsel) /Jose Caceres: Sending out meeting invites for today's phone call with opposingcounsel.
0.07 $250.00 $17.50
[W] SoFi [11] - 01/10/2018 - Document/File Managment / Daniel Strellman: Savingdocuments served on us to SP. Drafting, send for approval, and sending email to Dcounsel containing the evidence of the PAGA letter being sent and the PAGA letteritself to D counsel. Saving discovery requests sent for Zamaora to SP. Reviewingsaid discovery requests. Adding tasks re discovery to case. Drafting and sendingemail to L. Benowitz to confirm he can attend the 2/28 CMC. Updating CMS andother tasks in BC.
0.93 $150.00 $139.50
[W] SoFi [11] - 01/10/2018 - Communication (with opposition/outside counsel) /Daniel Strellman: Reviewing email from B. Weisenberg. Drafting and sending emailto opposing counsel. Reviewing individual rules. Calling the court to requestdiscovery help from the judge.
0.38 $150.00 $57.00
Page 21 of 52
[W] SoFi [11] - 01/10/2018 - Admin / Daniel Strellman: Updating CMS and othertasks in BC. Adding details from scheduling orders and the Court's Complex Dept.Rules. Saving document served on us (LB's NOA). Pinging RO to confirm whetheror not we will cancel the phone call with opposing counsel.
0.35 $150.00 $52.50
[W] SoFi [11] - 01/11/2018 - Admin / Daniel Strellman: Checking emails and courtinstructions for informal conferences. Calling court. Sending email detailing whatneed to be done to our attorneys.
0.35 $150.00 $52.50
[W] SoFi [11] - 01/11/2018 - Admin / Daniel Strellman: Adding tasks to case in BC. 0.14 $150.00 $21.00
[W] SoFi [11] - 01/12/2018 - Communcation (in firm) / Daniel Strellman: Meetingand instructions regarding filing the first amended complaint. Filing the firstamended complaint with J. Caceres with attached Order so that the clerk correctlyhandles the complaint.
0.57 $150.00 $85.50
[W] SoFi [11] - 01/12/2018 - Manage data/files / Jose Caceres: Filing First AmendComplaint and corresponding Order. *first filing on my own, going over it with DS.
[W] SoFi [11] - 01/16/2018 - Communcation (in firm) / Jose Caceres: ES clarifyingthe D's discovery request related task, showing me samples, etc.
0.25 $250.00 $62.50
[W] SoFi [11] - 01/16/2018 - Other Written Motions and Submissions / EricaSanders: Reviewing discovery requests sent from D counsel on Jan 9.
0.75 $450.00 $337.50
[W] SoFi [11] - 01/16/2018 - Document Production / Jose Caceres 0.45 $250.00 $112.50
[W] SoFi [11] - 01/16/2018 - Document Production / Jose Caceres: Draftingskeleton for the answer to form interrogatories.
1.02 $250.00 $255.00
[W] SoFi [11] - 01/17/2018 - Draft/Revise / Benjamin Weisenberg: Continuation:modify letters with factual background for J. Baum.
0.55 $550.00 $302.50
[W] SoFi [11] - 01/18/2018 - Written Discovery / Erica Sanders: Reviewingdiscovery and speaking to Jose.
0.37 $450.00 $166.50
[W] SoFi [11] - 01/18/2018 - Document Production / Jose Caceres: Addingdiscovery documents to Google Drive and creating folders for them in both SP andGD.
0.08 $250.00 $20.00
[W] SoFi [11] - 01/19/2018 - Written Discovery / Erica Sanders: Reviewingdiscovery requests and completing requests for admissions.
[W] SoFi [11] - 02/07/2018 - Document Production / Jose Caceres: BW's Pro HacApplication.
2.67 $250.00 $667.50
[W] SoFi [11] - 02/08/2018 - Document Production / Jose Caceres: BW's pro hacvice application. This includes adapting previous RO declarations, letter to PHVCounsel, proposed order and 4 POS. Calling the Wiss' court (being on hold for abit), told me the case was reassigned to Karnow. Changing doc where appropriateto reflect this. Filling out the credit card authorization form, and then redacting toinclude in the version to defendants. Creating 3 versions: one for defendants, oneto be filed and another to be sent to PHV counsel. Dealing iwth formatting.Proofreading. Speaking with Karnow's clerk to obtain a hearing date. Reviewing theorder assigning complex litigation to follow rules regarding PHV applications.Taking out mention of hearing dates in all 3 versions. Posting to BC for BW'sreview, including notes.
3.33 $250.00 $832.50
[W] SoFi [11] - 02/08/2018 - Review and Analyze / Robert Ottinger: reviewdocuments
0.60 $550.00 $330.00
[W] SoFi [11] - 02/09/2018 - Draft/Revise / Jose Caceres: Adding the other twoinstances in which Ben has applied for pro hac vice. Includes locating the signedorders granting the applications. Revising and reorganizing all 3 versions (1 tocourt, 1 to phv counsel and 1 to defendants), proofreading, uploading to drive.Printing POS to sign and upload to drive for D's version. Making a meeting invite toreview with BW. Skimming all three to make sure they are all formatted identically,and that pages are numbered correctly. Calling clerk to set a hearing date.Speaking with BW about what to do about the unopposed requirement for nohearing date. Emailing Ms. Reid. Revising all 3 versions appropriately.
[W] SoFi [11] - 02/12/2018 - Document/File Managment / Jose Caceres: Addingparagraph re application being unopposed to all 3 versions. Changing dates toreflect today, proofreading to ensure there are no mistakes. Preparing and printingshipping labels. Printing documents. Speaking with RO about the firm's File&ServeXpress account being delinquent. Looking up the court's local rules to see iffile and serve is the only approved method by which to file. Calling court severaltimes to ask about e-filing procedures.
1.48 $250.00 $370.00
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[W] SoFi [11] - 02/13/2018 - Communication (other external) / Jose Caceres: JudgeKarnow's clerk called back. Spoke about cancelling the hearing date and filingrequirements.
0.07 $250.00 $17.50
[W] SoFi [11] - 02/13/2018 - Admin / Jose Caceres: Changing dates on the 3 PHVversions to go ahead and file. Finally filing. Mailing out the application to the PHVcouncil and defendants.
0.62 $250.00 $155.00
[W] SoFi [11] - 02/14/2018 - Manage data/files / Anna Odoi: uploading felicia reidemail to drive; organizing folders
[W] SoFi [11] - 02/23/2018 - Communcation (in firm) / Erica Sanders:Communication with opposing counsel, RO and anna re JCMS.
0.17 $450.00 $76.50
[W] SoFi [11] - 02/23/2018 - Communcation (in firm) / Robert Ottinger:Communication with opposing counsel, ES, AO reg JCMS.
0.20 $550.00 $110.00
[W] SoFi [11] - 02/27/2018 - Admin / Anna Odoi: Creating case map 0.67 $150.00 $100.50
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[W] SoFi [11] - 02/28/2018 - Other / Erica Sanders: Sorting out CMC attendanceissue with
0.16 $450.00 $72.00
[W] SoFi [11] - 03/05/2018 - Other / Erica Sanders: Protective order stip. Readingoriginal, reading Brandon Charles stip to detect differences and compare.contrast.
[W] SoFi [11] - 03/07/2018 - Research / Nicholas Lunsford: researching whetherinaccurate wage statements can be certifiable re class action cases
1.44 $300.00 $432.00
[W] SoFi [11] - 03/07/2018 - Admin / Jose Caceres: Scanning mediationdocuments. Sending to Anna.
0.10 $250.00 $25.00
[W] SoFi [11] - 03/07/2018 - Communcation (in firm) / Nicholas Lunsford: preppingfor/call with ES about tasks for the case and what needs to be done to bring thecase along
0.39 $300.00 $117.00
[W] SoFi [11] - 03/07/2018 - Other / Erica Sanders: Meeting with Nick to discussdiscovery and damages.
0.25 $450.00 $112.50
[W] SoFi [11] - 03/07/2018 - Communcation (in firm) / Robert Ottinger: Discussionw/ES & NL to review discovery and damages
[W] SoFi [11] - 03/08/2018 - Document/File Managment / Nicholas Lunsford:arranging ultimate pleadings into a single location
0.17 $300.00 $51.00
[W] SoFi [11] - 03/08/2018 - Communcation (in firm) / Nicholas Lunsford: preppingfor/phone call with ES and LB re Cert
0.54 $300.00 $162.00
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[W] SoFi [11] - 03/08/2018 - Other / Erica Sanders: Call with Louis and Nick todiscuss certification challenges.
0.15 $450.00 $67.50
[W] SoFi [11] - 03/11/2018 - Research / Nicholas Lunsford: researching damagesto create cheatsheet
1.45 $300.00 $435.00
[W] SoFi [11] - 03/11/2018 - Draft/Revise / Nicholas Lunsford: creating and filling indamages cheatsheet
0.81 $300.00 $243.00
[W] SoFi [11] - 03/12/2018 - Review and Analyze / Nicholas Lunsford: reviewingcase file for info re employees hours, salary rates for damages cheatsheet
[W] SoFi [11] - 04/26/2018 - Review and Analyze / Anna Odoi: Looking at data fordamages, figuring out how realistic it is to complete damages before mediation
[W] SoFi [11] - 05/10/2018 - Draft/Revise / Ashley Pellouchoud: mediation brief;communication re same
6.75 $450.00 $3,037.50
[W] SoFi [11] - 05/10/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ A.Tom re damages
0.45 $450.00 $202.50
[W] SoFi [11] - 05/10/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ L.Benowitz re brief
0.30 $450.00 $135.00
[W] SoFi [11] - 05/10/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ A.Tom re damages
0.45 $450.00 $202.50
[W] SoFi [11] - 05/10/2018 - Case Assessment, Development and Administration /Anna Odoi: Making sure mediation brief exhibits refer to the correct document, batestamping, creating placeholder, emailing AP
[W] SoFi [11] - 06/28/2018 - Communcation (in firm) / Robert Ottinger: discussw/AP declaration from Legal Aid of Marin
0.10 $550.00 $55.00
[W] SoFi [11] - 07/02/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: re settlement agreement, MPA, etc.
0.15 $450.00 $67.50
[W] SoFi [11] - 07/05/2018 - Review and Analyze / Ashley Pellouchoud: SAC,settlement agreement; correspondence w/ F. Reid. I. Forgie, L. Benowitz, R.Ottinger re same
0.90 $450.00 $405.00
[W] SoFi [11] - 07/05/2018 - Review and Analyze / Robert Ottinger: SAC,settlement agreement; correspondence w/opp counsel, co counsel & AP reg same
0.90 $550.00 $495.00
Page 38 of 52
[W] SoFi [11] - 07/09/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ L.Benowitz re settlement administrators
0.10 $450.00 $45.00
[W] SoFi [11] - 07/09/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ B.Leary re settlement, etc.
0.50 $450.00 $225.00
[W] SoFi [11] - 07/10/2018 - Draft/Revise / Ashley Pellouchoud: settlementpaperwork; second amended complaint, etc.
0.74 $450.00 $333.00
[W] SoFi [11] - 07/10/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ L.Benowitz, R. Ottinger re MPA
0.10 $450.00 $45.00
[W] SoFi [11] - 07/10/2018 - Draft/Revise / Robert Ottinger: work w/AP & cocounsel; settlement paperwork; second amended complaint
0.83 $550.00 $456.50
[W] SoFi [11] - 07/11/2018 - Review and Analyze / Ashley Pellouchoud:correspondence from F. Reid re settlement
0.10 $450.00 $45.00
[W] SoFi [11] - 07/11/2018 - Research / Ashley Pellouchoud: re CCP 384;communication w/ L. Benowitz re distribution; correspondence w/ F. Reid re same
1.13 $450.00 $508.50
[W] SoFi [11] - 07/11/2018 - Communication (other external) / Ashley Pellouchoud:w/ class member A. Vera re settlement
0.20 $450.00 $90.00
[W] SoFi [11] - 07/12/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re settlement administrators
[W] SoFi [11] - 07/16/2018 - Communcation (in firm) / Anna Odoi: Calling client. 0.10 $150.00 $15.00
[W] SoFi [11] - 07/16/2018 - Communication (with client) / Ashley Pellouchoud: J.Baughman re settlement terms
0.35 $450.00 $157.50
[W] SoFi [11] - 07/16/2018 - Communication (with client) / Ashley Pellouchoud: K.Villegas re settlement terms
0.30 $450.00 $135.00
[W] SoFi [11] - 07/16/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: re stipulation to be filed; MPA deadline; data exchange
0.30 $450.00 $135.00
[W] SoFi [11] - 07/16/2018 - Communcation (in firm) / Robert Ottinger: Discuss callw/AP w/opp counsel re settlement terms
0.40 $550.00 $220.00
[W] SoFi [11] - 07/17/2018 - Communication (with client) / Anna Odoi: Uploadingsigned document, re-formatting the sent document, re-sending, drafting email
0.17 $150.00 $25.50
[W] SoFi [11] - 07/17/2018 - Admin / Anna Odoi: Calendaring new deadlines. 0.36 $150.00 $54.00
[W] SoFi [11] - 07/17/2018 - Communcation (in firm) / Anna Odoi: Firm meeting toreview case and update tasks and events.
[W] SoFi [11] - 07/31/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: re hearing dates, etc.
0.10 $450.00 $45.00
[W] SoFi [11] - 07/31/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ L.Benowitz re current drafts of MPA papers
0.10 $450.00 $45.00
[W] SoFi [11] - 07/31/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ A.Odoi re adequacy declaration
0.10 $450.00 $45.00
[W] SoFi [11] - 07/31/2018 - Communcation (in firm) / Robert Ottinger: w/AP & cocounsel reg current drafts of MPA papers
0.10 $550.00 $55.00
[W] SoFi [11] - 08/02/2018 - Communcation (in firm) / Anna Odoi: Internal meetingto discuss case and outstanding tasks and deadlines.
0.05 $150.00 $7.50
[W] SoFi [11] - 08/02/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: re confirmatory discovery, etc.
0.10 $450.00 $45.00
[W] SoFi [11] - 08/02/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: re confirmatory discovery, etc.
0.15 $450.00 $67.50
[W] SoFi [11] - 08/07/2018 - Communication (with client) / Ashley Pellouchoud: J.Bauhgman, K. Villegas, H. Landreth re settlement, etc.
0.35 $450.00 $157.50
[W] SoFi [11] - 08/07/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re draft MPA papers
0.10 $450.00 $45.00
[W] SoFi [11] - 08/08/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket, asking AP for date of hearing, calendaring dates.
0.13 $150.00 $19.50
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[W] SoFi [11] - 08/09/2018 - Case Assessment, Development and Administration /Anna Odoi: Drafting adequacy declaration.
[W] SoFi [11] - 08/13/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: re hearing, MPA deadline, draft motion, etc.
0.10 $450.00 $45.00
[W] SoFi [11] - 08/14/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket. Organizing files.
0.22 $150.00 $33.00
[W] SoFi [11] - 08/14/2018 - Communication (with client) / Anna Odoi: Checking tosee the status of the continuing of MPA hearing. Following up with AP.
0.19 $150.00 $28.50
[W] SoFi [11] - 08/14/2018 - Communication (with client) / Anna Odoi: Teammeeting to discuss case, updates, deadlines, and strategy.
0.05 $150.00 $7.50
[W] SoFi [11] - 08/16/2018 - Communcation (in firm) / Anna Odoi: Team meeting todiscuss case, updates, hearings, and deadlines.
0.08 $150.00 $12.00
[W] SoFi [11] - 08/17/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz, R. Ottinger re MPA papers, declaration ISO MPA, proposed order, etc.
0.10 $450.00 $45.00
[W] SoFi [11] - 08/17/2018 - Communication (other external) / Robert Ottinger:w/AP, co counsel re MPA papers, declaration ISO MPA, proposed order, etc.
[W] SoFi [11] - 08/20/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re preliminary approval motion
0.20 $450.00 $90.00
[W] SoFi [11] - 08/20/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: F. Reid, I. Forgie, L. Benowitz, R. Ottinger re motion forpreliminary approval
0.10 $450.00 $45.00
[W] SoFi [11] - 08/20/2018 - Review and Analyze / Robert Ottinger: motion forpreliminary approval
1.20 $550.00 $660.00
[W] SoFi [11] - 08/21/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket.
0.17 $150.00 $25.50
[W] SoFi [11] - 08/22/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re finalization of MPA papers
[W] SoFi [11] - 08/22/2018 - Review and Analyze / Ashley Pellouchoud: stipulationfor hearing dates; execute; circulate to I. Forgie, F. Reid, L. Benowitz, R. Ottinger,D. Galindo
0.30 $450.00 $135.00
[W] SoFi [11] - 08/23/2018 - Communication (other external) / Ashley Pellouchoud:S. Pullen re settlement administration, update
0.10 $450.00 $45.00
[W] SoFi [11] - 08/23/2018 - Communication (other external) / Ashley Pellouchoud:S. Pullen re settlement administration, etc.
0.40 $450.00 $180.00
[W] SoFi [11] - 08/23/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re motion, etc.
0.20 $450.00 $90.00
[W] SoFi [11] - 08/23/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz, F. Reid re damages calculations, MPA, class notice
0.40 $450.00 $180.00
[W] SoFi [11] - 08/24/2018 - Case Assessment, Development and Administration /Anna Odoi: Uploading filed stipulation.
0.10 $150.00 $15.00
[W] SoFi [11] - 08/24/2018 - Case Assessment, Development and Administration /Daniel Galindo: Receiving assignment for class notice
0.20 $300.00 $60.00
[W] SoFi [11] - 08/24/2018 - Communcation (in firm) / Ashley Pellouchoud: re classnotice
0.40 $450.00 $180.00
[W] SoFi [11] - 08/24/2018 - Class Action Certification and Notice / Daniel Galindo:Drafting class notice
[W] SoFi [11] - 08/26/2018 - Draft/Revise / Robert Ottinger: Motion for PreliminaryApproval
2.00 $550.00 $1,100.00
[W] SoFi [11] - 08/27/2018 - Draft/Revise / Ashley Pellouchoud: documents forMPA filing; communication w/ L. Benowitz re same
2.50 $450.00 $1,125.00
[W] SoFi [11] - 08/27/2018 - Review and Analyze / Daniel Galindo: Pre-filing reviewof documents
0.99 $300.00 $297.00
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[W] SoFi [11] - 08/29/2018 - Case Assessment, Development and Administration /Anna Odoi: Looking at filed OneLegal documents. Creating tasks.
0.12 $150.00 $18.00
[W] SoFi [11] - 08/29/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: re preliminary approval motion filing
0.10 $450.00 $45.00
[W] SoFi [11] - 08/29/2018 - Communication (other external) / Ashley Pellouchoud:One Legal re e-filing of motion for preliminary approval
1.06 $450.00 $477.00
[W] SoFi [11] - 08/30/2018 - Case Assessment, Development and Administration /Anna Odoi: Looking into status of MPA paperwork. Making sure everything hasbeen filed according to rules. Circulating information. Reviewing CA rules of court.
0.58 $150.00 $87.00
[W] SoFi [11] - 08/30/2018 - Case Assessment, Development and Administration /Anna Odoi: Calling OneLegal re: e-filing. Re-filing MPA paperwork via ServeXpress. Calling Xpress.
1.42 $150.00 $213.00
[W] SoFi [11] - 08/30/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ A.Odoi re motion for preliminary approval filing
0.20 $450.00 $90.00
[W] SoFi [11] - 08/30/2018 - Case Assessment, Development and Administration /Anna Odoi: Drafting stipulation to file SAC.
0.39 $150.00 $58.50
[W] SoFi [11] - 08/31/2018 - Case Assessment, Development and Administration /Anna Odoi: Editing drafted stipulation to file SAC. Texting DL instructions
0.20 $150.00 $30.00
[W] SoFi [11] - 08/31/2018 - Review and Analyze / Daniel Galindo: Draft jointstipulation & order
0.25 $300.00 $75.00
[W] SoFi [11] - 08/31/2018 - Case Assessment, Development and Administration /Anna Odoi: Uploading documents.
0.04 $150.00 $6.00
[W] SoFi [11] - 09/04/2018 - Case Assessment, Development and Administration /Anna Odoi: Looking into SAC Filing. Asking attorney for help.
0.18 $150.00 $27.00
[W] SoFi [11] - 09/04/2018 - Communcation (in firm) / Anna Odoi: Talking to AP refiling
0.03 $150.00 $4.50
[W] SoFi [11] - 09/05/2018 - Communcation (in firm) / Anna Odoi: Filing stipulationto file SAC. Contacting court.
0.51 $150.00 $76.50
[W] SoFi [11] - 09/06/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket.
0.03 $150.00 $4.50
[W] SoFi [11] - 09/07/2018 - Communcation (in firm) / Anna Odoi: GOing over taskswith AP.
0.07 $150.00 $10.50
[W] SoFi [11] - 09/07/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket to confirm MPA hearing and checking tent rulings
0.08 $150.00 $12.00
[W] SoFi [11] - 09/10/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket for tentative ruling
0.04 $150.00 $6.00
Page 45 of 52
[W] SoFi [11] - 09/10/2018 - Review and Analyze / Ashley Pellouchoud:correspondence from K. Villegas re settlement
0.10 $450.00 $45.00
[W] SoFi [11] - 09/10/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket for tentative ruling again.
0.03 $150.00 $4.50
[W] SoFi [11] - 09/10/2018 - Trial and Hearing Attendance / Ashley Pellouchoud:prepare for Motion for Preliminary Approval of Class Action Settlement
1.68 $450.00 $756.00
[W] SoFi [11] - 09/10/2018 - Case Assessment, Development and Administration /Anna Odoi: Calling Court re: SAC Filing. Looking into filing.
0.10 $150.00 $15.00
[W] SoFi [11] - 09/10/2018 - Trial and Hearing Attendance / Ashley Pellouchoud:prepare for Motion for Preliminary Approval of Class Action Settlement
2.30 $450.00 $1,035.00
[W] SoFi [11] - 09/11/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking status of SAC. Tentative ruling.
0.07 $150.00 $10.50
[W] SoFi [11] - 09/11/2018 - Trial and Hearing Attendance / Ashley Pellouchoud:prepare for Motion for Preliminary Approval of Class Action Settlement
4.50 $450.00 $2,025.00
[W] SoFi [11] - 09/11/2018 - Case Assessment, Development and Administration /Anna Odoi: Calling court to confirm filing of SAC.
0.03 $150.00 $4.50
[W] SoFi [11] - 09/11/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking tentative ruling.
[W] SoFi [11] - 09/11/2018 - Appear for/Attend / Daniel Galindo: Mot. for Prelim.Approval (AO appearing)
2.00 $300.00 $600.00
[W] SoFi [11] - 09/12/2018 - Case Assessment, Development and Administration /Anna Odoi: Calling court re: SAC. Calling File and Xpress. Looking at docket.Circulating status of SAC to attorney
0.43 $150.00 $64.50
[W] SoFi [11] - 09/12/2018 - Case Assessment, Development and Administration /Anna Odoi: Reviewing File and Serve Xpress notification.
0.09 $150.00 $13.50
[W] SoFi [11] - 09/13/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: F. Reid and L. Benowitz re motion for preliminary approval ofclass action settlement
0.30 $450.00 $135.00
[W] SoFi [11] - 09/14/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket. Looking into status of stipulation to file SAC
0.07 $150.00 $10.50
[W] SoFi [11] - 09/17/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket to see if stipuatlion re SAC is granted. Calling File andServe Xpress
0.13 $150.00 $19.50
Page 46 of 52
[W] SoFi [11] - 09/17/2018 - Communication (other external) / Anna Odoi: CallingClerk regarding the status of stipulation to file SAC. Circulating information.
0.18 $150.00 $27.00
[W] SoFi [11] - 09/18/2018 - Case Assessment, Development and Administration /Anna Odoi: Looking into stipulation to file SAC.
0.08 $150.00 $12.00
[W] SoFi [11] - 09/19/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking docket and status of SAC stip.
[W] SoFi [11] - 09/19/2018 - Communication (with client) / Ashley Pellouchoud: K.Villegas re adequacy declaration
0.15 $450.00 $67.50
[W] SoFi [11] - 09/19/2018 - Communication (with client) / Ashley Pellouchoud: J.Baughman re adequacy declaration
0.07 $450.00 $31.50
[W] SoFi [11] - 09/19/2018 - Communication (with client) / Ashley Pellouchoud: B.Miles re adequacy declaration
0.25 $450.00 $112.50
[W] SoFi [11] - 09/19/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re motion for preliminary approval
0.20 $450.00 $90.00
[W] SoFi [11] - 09/19/2018 - Review and Analyze / Ashley Pellouchoud:correspondence from F. Reid re settlement papers, next steps
0.10 $450.00 $45.00
[W] SoFi [11] - 09/20/2018 - Case Assessment, Development and Administration /Anna Odoi: Drafting declarations of all named Plaintiffs in support of finalsettlement. Emailing plaintiffs for missing information. Editing declaration asinformation rolls in.
0.65 $150.00 $97.50
[W] SoFi [11] - 09/20/2018 - Communication (other external) / Anna Odoi: CallingCourt about SAC stipulation
0.08 $150.00 $12.00
[W] SoFi [11] - 09/20/2018 - Draft/Revise / Ashley Pellouchoud: adequacydeclarations; communication with clients re same
1.60 $450.00 $720.00
[W] SoFi [11] - 09/21/2018 - Case Assessment, Development and Administration /Anna Odoi: Downloading and uploading granted order to file SAC. Filing SAC.Circulating information.
0.23 $150.00 $34.50
[W] SoFi [11] - 09/21/2018 - Case Assessment, Development and Administration /Anna Odoi: Sending Plaintiffs declarations to sign. Preparing documents forsigning. Drafting message.
0.57 $150.00 $85.50
[W] SoFi [11] - 09/24/2018 - Case Assessment, Development and Administration /Anna Odoi: Uploading signed declarations to Drive.
0.20 $150.00 $30.00
[W] SoFi [11] - 09/24/2018 - Case Assessment, Development and Administration /Anna Odoi: Downloading and uploading Baughman signed declaration.
0.13 $150.00 $19.50
Page 47 of 52
[W] SoFi [11] - 09/24/2018 - Review and Analyze / Ashley Pellouchoud: finaldeclarations ISO preliminary approval; circulate to L. Benowitz
0.30 $450.00 $135.00
[W] SoFi [11] - 09/24/2018 - Communication (other external) / Ashley Pellouchoud:F. Reid re MPA paperwork
0.10 $450.00 $45.00
[W] SoFi [11] - 09/24/2018 - Draft/Revise / Ashley Pellouchoud: motion forpreliminary approval paperwork; Ottinger declaration; communication w/ L.Benowitz re same
1.65 $450.00 $742.50
[W] SoFi [11] - 09/24/2018 - Draft/Revise / Robert Ottinger: Work on motion forpreliminary approval paperwork; work w/co counsel reg declaration
0.50 $550.00 $275.00
[W] SoFi [11] - 09/25/2018 - Other Written Motions and Submissions / AshleyPellouchoud: draft/revise/coordinate filing of Supplemental Memorandum of Pointsand Authorities ISO Preliminary Approval
0.97 $450.00 $436.50
[W] SoFi [11] - 09/25/2018 - Communcation (in firm) / Anna Odoi: Going over MPAsupplremental briefing task with AP.
0.20 $150.00 $30.00
[W] SoFi [11] - 09/25/2018 - Case Assessment, Development and Administration /Anna Odoi: Filing supplemental motion for preliminary approval paperwork. CallingFile and XServe. Emailing Department copy of Order.
0.48 $150.00 $72.00
[W] SoFi [11] - 09/27/2018 - Communication (other external) / Ashley Pellouchoud:class member P. Lopez re class action claims
0.10 $450.00 $45.00
[W] SoFi [11] - 10/01/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ D.Galindo, A. Odoi re administration of settlement
0.20 $450.00 $90.00
[W] SoFi [11] - 10/01/2018 - Admin / Anna Odoi: Adding contact information ofsettlement admin to HR.
0.06 $150.00 $9.00
[W] SoFi [11] - 10/01/2018 - Case Assessment, Development and Administration /Daniel Galindo: Contact spreadsheet
0.27 $300.00 $81.00
[W] SoFi [11] - 10/02/2018 - Case Assessment, Development and Administration /Daniel Galindo: Class member contact
0.14 $300.00 $42.00
[W] SoFi [11] - 10/03/2018 - Trial and Hearing Attendance / Ashley Pellouchoud:prepare for Motion for Preliminary Approval hearing
0.75 $450.00 $337.50
[W] SoFi [11] - 10/04/2018 - Admin / Anna Odoi: Checking docket.Preparing/getting info for MPA hearing. COordinating with AP and LB to set upcourtcall. Calling LB and texting him. Calling Court. Circulating information toattorneys.
0.52 $150.00 $78.00
[W] SoFi [11] - 10/04/2018 - Trial and Hearing Attendance / Ashley Pellouchoud:prepare for Motion for Preliminary Approval
1.16 $450.00 $522.00
[W] SoFi [11] - 10/04/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking status of MPA filing and changes made.
0.07 $150.00 $10.50
Page 48 of 52
[W] SoFi [11] - 10/04/2018 - Trial and Hearing Attendance / Ashley Pellouchoud:review tentative; communication w/ L. Benowitz re same
0.70 $450.00 $315.00
[W] SoFi [11] - 10/05/2018 - Trial and Hearing Attendance / Ashley Pellouchoud:Motion for Preliminary Approval
0.50 $450.00 $225.00
[W] SoFi [11] - 10/05/2018 - Trial and Hearing Attendance / Ashley Pellouchoud:prepare for Motion for Preliminary Approval
2.20 $450.00 $990.00
[W] SoFi [11] - 10/05/2018 - Communication (other external) / Ashley Pellouchoud:H. Landreth re settlement administration
0.10 $450.00 $45.00
[W] SoFi [11] - 10/08/2018 - Case Assessment, Development and Administration /Daniel Galindo: Class contact management
0.03 $300.00 $9.00
[W] SoFi [11] - 10/08/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: and L. Benowitz re supplemental briefing tasks, etc.
0.25 $450.00 $112.50
[W] SoFi [11] - 10/08/2018 - Project Management / Ashley Pellouchoud:supplemental Motion for Preliminary approval; edit tasks as necessary, etc.
[W] SoFi [11] - 10/09/2018 - Case Assessment, Development and Administration /Anna Odoi: Reviewing case and tasks.
0.03 $150.00 $4.50
[W] SoFi [11] - 10/09/2018 - Case Assessment, Development and Administration /Anna Odoi: Editing declarations re: MPA per AP comments. Finalizing format andorganizing docs. Creating task for review.
0.32 $150.00 $48.00
[W] SoFi [11] - 10/09/2018 - Case Assessment, Development and Administration /Anna Odoi: Looking into intake message from SoFi class member. Circulating infoto DG.
0.07 $150.00 $10.50
[W] SoFi [11] - 10/09/2018 - Case Assessment, Development and Administration /Daniel Galindo: Class member contact tracking and calling
0.13 $300.00 $39.00
[W] SoFi [11] - 10/09/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re next steps, supplemental briefing, etc.
[W] SoFi [11] - 10/10/2018 - Review and Analyze / Ashley Pellouchoud:correspondence from L/ Benowitz re stipulation to amend settlement agreementand supplemental preliminary approval papers
0.20 $450.00 $90.00
[W] SoFi [11] - 10/10/2018 - Case Assessment, Development and Administration /Daniel Galindo: Updating class member contact list
0.06 $300.00 $18.00
Page 49 of 52
[W] SoFi [11] - 10/11/2018 - Review and Analyze / Ashley Pellouchoud:correspondence from F. Reid, L. Benowitz re settlement, stipulation, etc.
0.25 $450.00 $112.50
[W] SoFi [11] - 10/12/2018 - Communication (with client) / Ashley Pellouchoud:named Plaintiffs re amended settlement agreement, revised declarations, updatefrom Court, etc.
1.07 $450.00 $481.50
[W] SoFi [11] - 10/12/2018 - Communcation (in firm) / Robert Ottinger: meet w/APreg amended settlement agreement, revised declarations, update from Court, etc.
0.40 $550.00 $220.00
[W] SoFi [11] - 10/15/2018 - Case Assessment, Development and Administration /Anna Odoi: Uploading declarations ISO settlement. Organizing files and finalizingformat. Circulating information to AP and attorneys. Following up with baughmanre: signing.
0.33 $150.00 $49.50
[W] SoFi [11] - 10/15/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ J.Baughman re settlement, amendments to settlement; responding to Court order
[W] SoFi [11] - 10/15/2018 - Communication (with client) / Ashley Pellouchoud: J.Baughman re amended settlement agreement, preliminary approval paperwork
0.20 $450.00 $90.00
[W] SoFi [11] - 10/16/2018 - Case Assessment, Development and Administration /Anna Odoi: Uploading signed Baughman declaration. Circulating info.
0.05 $150.00 $7.50
[W] SoFi [11] - 10/16/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: I. Forgie re revisions to notice, procedure for editing finalversion
0.10 $450.00 $45.00
[W] SoFi [11] - 10/16/2018 - Case Assessment, Development and Administration /Anna Odoi: Finalizing format of declaraations. Combining, organizing. Coordinatingwith AP.
0.25 $150.00 $37.50
[W] SoFi [11] - 10/16/2018 - Communcation (in firm) / Ashley Pellouchoud: w/ A.Odoi re supplemental briefing, tasks re documents for filing
0.05 $450.00 $22.50
[W] SoFi [11] - 10/16/2018 - Case Assessment, Development and Administration /Anna Odoi: Separating pages/declarations/SA. Redacting typos. Finalizing anduploading.
[W] SoFi [11] - 10/16/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re documents for 10/19 filing
0.23 $450.00 $103.50
[W] SoFi [11] - 10/16/2018 - Case Assessment, Development and Administration /Anna Odoi: Checking dockets.
0.10 $150.00 $15.00
[W] SoFi [11] - 10/17/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re filing papers Friday
0.06 $450.00 $27.00
[W] SoFi [11] - 10/18/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re supplemental filing
0.10 $450.00 $45.00
[W] SoFi [11] - 10/18/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: re final executed settlement agreement, amended
0.25 $450.00 $112.50
[W] SoFi [11] - 10/18/2018 - Draft/Revise / Ashley Pellouchoud: supplementalbriefing paperwork; review final drafts; communication w/ L. Benowitz re same
[W] SoFi [11] - 10/18/2018 - Communcation (in firm) / Robert Ottinger: meetingw/co counsel reg supplemental filing & AP
0.10 $550.00 $55.00
[W] SoFi [11] - 10/19/2018 - Case Assessment, Development and Administration /Anna Odoi: Coordinating with DG and ES re: filing of supplemental MPApaperwork. Editing paperwork and finalizing. Calling court. Filing via file xpress.Sending proposed order via email to department. Calling court. Circulatinginformation.
[W] SoFi [11] - 10/19/2018 - Communcation (in firm) / Ashley Pellouchoud: re filingof MPA
0.20 $450.00 $90.00
[W] SoFi [11] - 10/24/2018 - Case Assessment, Development and Administration /Anna Odoi: Looking into status of MPA paperwork. Circulating info. Creatingcourtesy copy order via onelegal.
0.45 $150.00 $67.50
[W] SoFi [11] - 10/24/2018 - Communication (other external) / Ashley Pellouchoud:Court re preliminary settlement approval
0.10 $450.00 $45.00
[W] SoFi [11] - 10/24/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: I. Forgie re call with Court
0.15 $450.00 $67.50
[W] SoFi [11] - 10/24/2018 - Communication (with opposition/outside counsel) /Ashley Pellouchoud: I. Forgie re court hearing Friday
0.20 $450.00 $90.00
[W] SoFi [11] - 10/24/2018 - Communication (other external) / Ashley Pellouchoud:department 304 re conference call w/ Judge Karnow
0.10 $450.00 $45.00
Page 51 of 52
[W] SoFi [11] - 10/24/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re court appearance Friday 10/26; court, etc. re same; tee-upconference call information
0.30 $450.00 $135.00
[W] SoFi [11] - 10/26/2018 - Communication (other external) / Ashley Pellouchoud:L. Benowitz re instructions from the Court, next steps, preliminary approval;communication in firm re same
0.30 $450.00 $135.00
[W] SoFi [11] - 10/30/2018 - Case Assessment, Development and Administration /Anna Odoi: Coordinating with attorneys re stipulation. Affixing RO signature to stip.Sending to LB>
0.20 $150.00 $30.00
[W] SoFi [11] - 10/30/2018 - Case Assessment, Development and Administration /Anna Odoi: Drafting and creating POS for LB. Sending to LB. Filing the stipulationand declaration IS. Submitting court. delivery order.
0.52 $150.00 $78.00
[W] SoFi [11] - 10/31/2018 - Case Assessment, Development and Administration /Daniel Galindo: Updating class member contact info
0.01 $300.00 $3.00
[W] SoFi [11] - 10/31/2018 - Review and Analyze / Ashley Pellouchoud: ordergranting preliminary approval of class action settlement; related docket entries;communication re same
0.40 $450.00 $180.00
[W] SoFi [11] - 08/22/2019 - Review and Analyze / Robert Ottinger: stipulation forhearing dates; execute; circulate to co counsel, opp counsel, AP & DG
0.30 $550.00 $165.00
Amount Due $207,689.50
Page 52 of 52
The Ottinger Firm, PC535 Mission Street, 14th FloorSan Francisco , California 94105United States
INVOICEInvoice # 244
Date: 02/19/2019Due Upon Receipt
SoFi
SoFi
Wage & Hour Class Action
Type Date Notes Quantity Rate Total
Service 11/01/2018 Case Assessment, Development and Administration:Tasks related to settlement administration. Uploadingorder. Uploading relevant deadlines. Reviewing orderfor tasks.
0.30 $150.00 $45.00
Service 11/02/2018 Communication (other external): A. Vera re settlementadministration
0.20 $450.00 $90.00
Service 11/06/2018 Communication (with client): J. Baughman repreliminary approval, etc.
0.30 $450.00 $135.00
Service 11/07/2018 Case Assessment, Development and Administration:Gathering requested docs to send to case admin.
0.40 $150.00 $60.00
Service 11/08/2018 Case Assessment, Development and Administration:Corresponding with settlement admin.
0.10 $150.00 $15.00
Service 11/08/2018 Case Assessment, Development and Administration:Checking docket.
0.10 $150.00 $15.00
Service 11/08/2018 Communication (other external): w/ administrator repreliminary approval of settlement order deadlines
0.20 $300.00 $60.00
Service 11/08/2018 Communication (other external): class member H.Landreth re preliminary approval order, etc.
0.20 $450.00 $90.00
Service 11/09/2018 Communication (with client): re updating contact info w/settlement administrator & case update
0.30 $300.00 $90.00
Service 11/09/2018 Communication (internal): re instructions for updatingclass members
0.20 $300.00 $60.00
Page 1 of 3
Service 11/09/2018 Communication (in firm): w/ D. Galindo, R. Ottinger resettlement, procedure, communication w/ classmembers, etc.
0.30 $450.00 $135.00
Service 11/09/2018 Communication (in firm): w/AP & DG 0.30 $550.00 $165.00
Service 11/12/2018 C400 - Third Party Communication: w. A. Chow resettlement administration costs
0.20 $450.00 $90.00
Service 11/13/2018 Case Assessment, Development and Administration:Calculating costs. Updating cossts of case.
0.30 $150.00 $45.00
Service 11/13/2018 Case Assessment, Development and Administration:Re-calculating costs and adding costs.
0.30 $150.00 $45.00
Service 11/15/2018 Draft/Revise: class notice 0.40 $450.00 $180.00
Service 11/16/2018 Case Assessment, Development and Administration:Reviewing dockets. Reviewing orders for any deadlinesnot on calendars. Uploading all deadlines. Circulatinginfo
0.30 $150.00 $45.00
Service 11/16/2018 Admin: Updating class member contact info 0.10 $300.00 $30.00
Service 11/19/2018 Admin: updating contact info for class members 0.10 $300.00 $30.00
Service 11/28/2018 Communication (other external): w/ J. Baughman, H.Ripa, B. Walker, A. Chow, et al. re notice of settlement,settlement administration, etc.
0.90 $450.00 $405.00
Service 11/30/2018 Review and Analyze: filing by Defendant 0.10 $450.00 $45.00
Service 12/07/2018 Communication (other external): w/ A. Chow resettlement administration; updated contacts
0.30 $450.00 $135.00
Service 12/16/2018 Case Assessment, Development and Administration:Calendaring time to discuss trigger dates
0.10 $300.00 $30.00
Service 12/18/2018 Communication (with opposition/outside counsel): recase management, next steps
0.40 $450.00 $180.00
Service 02/07/2019 Review motion for approval materials. Stip to continue.Calls with local counsel.
1.80 $550.00 $990.00
Service 02/14/2019 Calls with Local Counsel. Review motion for finalapproval and supporting docs.
5.30 $550.00 $2,915.00
Expense 02/15/2019 Reimbursable expense: OneLegal Receipt forStipulation and Proposed Order
1.00 $32.00 $32.00
Service 02/18/2019 Drafting: Declaration of RO in support of motion for finalapproval.
2.00 $550.00 $1,100.00
Expense 02/19/2019 Reimbursable expense: OneLegal Receipt forStipulation and Proposed Order (2) See ClioDocuments, Admin & Billing folder.
1.00 $51.95 $51.95
Invoice # 244 - 02/19/2019
Page 2 of 3
Service 02/19/2019 Document Production: Worked on Declaration for FinalApproval - Edited the format.
0.20 $150.00 $30.00
Total $7,338.95
Please make all amounts payable to: The Ottinger Firm, PC
Payment is due upon receipt.
Invoice # 244 - 02/19/2019
Page 3 of 3
EXHIBIT 2
A S H L E Y P E L L O U C H O U D (309) 299-0160 × [email protected]
PROFESSIONAL EXPERIENCE SIEGEL LEWITTER MALKANI, OAKLAND, CA × Associate March 2017—Present
Responsibilities: Manage plaintiff-side individual/class action employment and public interest (wage/hour, wrongful term., whistleblower, Parity Act, sexual assault) caseload × Draft motions, pleadings, administrative complaints, discovery requests/responses, demand letters, mediation briefs × Coordinate meet and confer efforts × Participate in negotiating settlement and settlement agreements × Monitor complex SOL/exhaustion deadlines × Spearhead discovery efforts × Prepare statistical analyses × Develop case theories × Court appearances as necessary. Cases: Major contributor to case/settlement (> $2.5 million, indiv. civil rights); co-drafted successful discovery motion (major CA class action).
THE LIU LAW FIRM, P.C. , SAN FRANCISCO, CA × Associate Oct. 2015—March 2017
Responsibilities: Investigated, evaluated, and litigated plaintiff-side individual/class action employment (wage/hour, wrongful term.) and sexual assault cases × Drafted motions, pleadings, discovery, demand letters, declarations, mediation briefs, contracts, and retainer agreements × Coordinated class settlement administration (FLSA/state law) × Managed discovery (>40,000 pages + repositories) × Recruited class reps. × Built business × Prepared and defended clients in deposition × Managed firm caseload. Cases: Major contributor to significant settlements (> $2 million, indiv. civil rights; $3.65m, misclassification/wage and hour class action; $297,000, wage and hour class action; $225,000, indiv. sexual orientation discrimination; > $200,000, indiv. gender discrimination).
OUTTEN & GOLDEN LLP, SAN FRANCISCO, CA × Staff Attorney March 2014—Oct. 2015
Responsibilities: Investigated, evaluated, and helped launch multi-state FLSA/state law class action × Drafted complex consolidated FLSA state law hybrid complaint (8 states), 216(b) motion, partial MSJ, discovery, and class member declarations × Team member on successful 9th Cir. brief (arbitration) × Led successful 2-month 50+ mediation declaration project × Prepared and defended clients in depositions × Reviewed and summarized complex evidentiary records × Recruited class representatives × Supervised law clerks and contract attorneys. Cases: Major contributor (450+ hrs) on case that resulted in $9.25m settlement (off-the-clock class action).
ENVIRONMENTAL LAW & JUSTICE CLINIC, SAN FRANCISCO, CA × Graduate Fellow Jan. 2013—March 2014
Responsibilities: Won appeal against EPA × Co-drafted successful discovery motion won sanctions × Drafted motions, pleadings, FOIA and PRA requests, and research memoranda × Presented oral testimony to municipal agency.
EDUCATION & HONORS Golden Gate University School of Law, San Francisco, CA × J.D. 2012 Specializations: Public Interest Law × Environmental Law Positions: Environmental Law Journal, Associate Editor × Moot Court Board, Appointee
Honors: National Semifinalist, Williams Institute Moot Court (2012) × Witkin, Appellate Advocacy (2010) × CALI, Environmental Moot Court (2012) × CALI, Special Problems in Real Property (2012) × Dean’s List (2010—2012)
California State University, East Bay, Hayward, CA × B.A. 2005 Knox College, Galesburg, IL × NCAA Basketball 2001—2003
CURRENT ACTIVITIES Positions BALIF Board Member (April 2016—Present) × ABA National LGBT Bar Association Delegate to the Young
McGill University, Faculty of Law, Montreal Bachelor of Civil Law (BCL) and Bachelor of Laws (LL.B.) (Equivalent J.D.)
2015
San Francisco State University, Faculty of Arts M.A. in Social Psychology B.A. in Psychology/Minor in International Business
2011 2009
Selected Work Experience
Freshfields Bruckhaus Deringer LLP, Dubai UAE Law Clerk • Assisted in trial preparation, including document production, performing
research, drafting pleadings, and preparing scripts for cross-examination of witnesses
• Assisted in preparing a multinational technology company for mediation proceedings commenced by its distributor regarding a terminated distribution agreement
• Reviewed contracts and prepared due diligence reports in relation to potential cross-border acquisition of shares
November 2016-June
2017
Orrick, Herrington & Sutcliffe LLP, Paris France International Arbitration Intern • Assisted arbitration team in its representation of the Guinean government,
successfully defeating an investor’s expropriation claims • Prepared senior partners for various conference presentations and speaking
engagements such as the Annual International Arbitration Day • Assisted in a wide range of non-contentious advisory matters particularly related
to the drafting of arbitration clauses
January-May 2015
International Court of Arbitration of the International Chamber of Commerce (ICC Court), Paris France Legal Intern • Analysed party submissions under the ICC Rules and drafted memoranda for the
ICC Court • Reviewed arbitral awards under the supervision of Counsel to ensure compliance
with ICC standards • Performed research in the fields of international litigation, arbitration, and
EDUCATION Juris Doctor - Capital University Law School, May 2011 - Columbus, Ohio
• Honors: Cum Laude, five time Dean’s List award winner and Litigation Concentration • Capital University Law Review (Only top 10% of rising 2Ls selected)
B.A. - The Ohio State University, June 2008 - Columbus, Ohio
• Major: Criminology; Minor: Sociology
LICENSED • New York State, Washington State and Washington, D.C. • U.S. District Court for the Southern and Eastern Districts of New York
EXPERIENCE Law Office of Everett Carbajal, P.C. - New York, New York
Associate Attorney August 2015 – Present • Represent small to medium sized businesses in all stages of development, operations, litigation and acquisitions • Develop out and market the firm’s litigation practice, as well as assist the firm in focusing on proactively protecting its
corporate clients from potential future disputes through narrowly tailored contractual provisions • Expand the firm’s focus on negotiating for modifications to standard Supplier/Purchaser agreements to better protect
clients’ Intellectual Property, qualify clients’ representations and warranties and limit the scope of clients’ liability Musa-Obregon & Associates - New York, New York
Associate Attorney January 2012 – August 2015 • Assisted businesses and individuals protect their legal rights and redress wrongful conduct by pursuing and defending
lawsuits before the U.S. District Courts for the Southern and Eastern New York and New York State Supreme Court • Implemented a strategy of assertive pre-trial motion practice, targeted depositions and proactive negotiations with
opposing counsel to routinely achieve favorable settlements • Coordinated investigations to discover facts, identify witnesses and obtain documentation in support of litigation • Effectively communicated to clients the benefits of resolving matters to avoid unnecessary litigation expenses when
appropriate given the individual facts and circumstances of a specific matter • Energized the firm’s brand recognition as a high volume litigation practice by successfully representing over 100
businesses and individuals before the state and federal courts while simultaneously launching a pro bono community outreach program, which resulted in the opening of two additional offices to meet increased demand
• Advanced the firm’s reputation with governing authorities by turning down settlement offers and achieving clients’ desired results through bench and jury trials
• Directed and trained a team of two associates, two junior associates and six paralegals • Mentored two junior associates who received promotions to associate faster than the standard time in stage • Implemented a staff evaluation system to identify and maximize individual employees’ potential, and demonstrably
increased paralegal productivity through the selection and implementation of new legal management software United States Attorney’s Office, Southern District of Ohio – Columbus, Ohio
Summer Law Clerk May 2010 – September 2010 • One of only five law students selected for the summer clerkship with the Columbus Office of the USAO • Legal research and writing on behalf of Assistant United States Attorneys appearing before the U.S. District Courts and
the 6th Circuit Court of Appeals, as well as third chair trial experience before the U.S. District Court
COMMITTEES • New York City Bar Association New Lawyer’s Counsel, Practice and Skills Committee June 2014 – Pres.
EXHIBIT 5
D A N I E L H . G A L I N D O 1 7 4 H e r m a n n S t r e e t | S a n F r a n c i s c o , C A 9 4 1 0 2 | ( 4 1 5 ) 6 9 6 - 0 1 1 0 | g a l i n d o @ u c h a s t i n g s . e d u
UC HASTINGS COLLEGE OF THE LAW San Francisco, CA Juris Doctor Aug. 2015 – May 2018 • Tony Patiño Fellowship: substantial scholarship & mentorship for demonstrated public service commitment • Hastings Appellate Project: student counsel in Ninth Circuit appeal Fall 2017 – Spring 2018 • Hastings Law Journal, Production Editor; Staff Editor Fall 2016 – Spring 2018 • Moot Court, Board Member Fall 2017 – Spring 2018
o Chicago Bar Association Moot Court Competition, Student Coach Fall 2017 o ABA Nat’l Appellate Advocacy Competition, 1st Place Brief Winner & Semi-Finalist Spring 2017
• Teaching Assistant: Appellate Advocacy – Prof. Mari Overbeck, [email protected] Fall 2017 Legal Research & Writing – Prof. Michael Gowe, [email protected] Fall 2016
• Hastings American Constitutional Society, Chair Fall 2016 – Spring 2018 • Hastings Students for Immigrants’ Rights, Treasurer Fall 2016 – Spring 2017 • Hastings OUTLAW, Community Chair Fall 2016 – Spring 2017 • Legal Advice & Referral Clinic; Center for Gender & Refugee Studies; Individual Representation Clinic
Volunteer Interpreter (as needed) TRINITY UNIVERSITY San Antonio, TX B.A. Political Science & International Studies Double Major, French Minor Aug. 2005 – May 2009 • Study Abroad: University of Jordan, Amman, Jordan Spring 2008 • Trinity University First Generation-Underrepresented Students Cohort Co-Founder Fall 2007 – 2009 • Latino Exchange (Student Cultural Group) President Fall 2006 – Spring 2007
EXPERIENCE
THE OTTINGER FIRM, P.C., San Francisco, CA August 2018 – Present Associate supervised by Robert Ottinger, [email protected]
ROSEN, BIEN, GALVAN & GRUNFELD L.L.P., San Francisco, CA Summer 2017 Law Clerk supervised by Krista Stone-Manista, [email protected]
LAWYERS’ COMMITTEE FOR CIVIL RIGHTS, San Francisco, CA Summer 2016 Law Clerk supervised by Travis Silva, [email protected]
ACLU NATIONAL, IMMIGRANTS’ RIGHTS PROJECT, San Francisco, CA Dec. 2013 – March 2015 Paralegal supervised by Cecillia Wang, [email protected] FREELANCE ENGLISH TUTOR, Karlsruhe/Hamburg, Germany Nov. 2012 – July 2013
ACLU OF NORTHERN CALIFORNIA, San Francisco, CA Program Associate supervised by Abdi Soltani, [email protected] March 2015 – June 2015 Community Organizer supervised by Shayna Gelender, [email protected] Oct. 2009 – Oct. 2012
LABOR COUNCIL FOR LATIN AMERICAN ADVANCEMENT, Washington, D.C. Summer 2009 Intern supervised by Hector Sanchez, [email protected]
LANGUAGES
Fluency in written and spoken Spanish (i.e. native proficiency and experienced in interpretation/translation) | Conversational in French and German | Beginner’s proficiency in Arabic.
INTERESTS
Triathlon, open water swimming | Opera, classical music, and ballet | Traveling (17 countries visited)
EXHIBIT 6
Nicholas A. Lunsford 1516StillwellRd•SanFrancisco,CA94129(925)818-1743•[email protected]
EDUCATION
University of California, Hastings College of the Law, San Francisco, CA Juris Doctor, May 2017
UC Hastings Communications and Entertainment Law Journal Operations Editor, 2016-17
UC Hastings Association of Communication, Sports and Entertainment Law Club President, 2016-17
Vice President of Public Relations/Social Media, 2015-16 University of California, Davis, Davis, CA Bachelor of Arts, Communications & History, June 2013 UC Davis Rugby Team, 2009-2013
PROFESSIONAL EXPERIENCE
Law Office of Richard J. Vaznaugh – San Francisco, CA Senior File Clerk/Contract Attorney, October 2017 – current
• In-depth practice of pregnancy discrimination and leave laws, such as the PDLL, FMLA, and CFRA
• Created Demand Letter for settlement from client’s employer and filed Complaint • Performed substantial legal research through WestLaw and other research tools
Law Offices of Nancy E. Hudgins – San Francisco/Walnut Creek, CA File Clerk, May 2015 – May 2017
• Propounded discovery requests and responses, correspondence to opposing party, and handled filings with state and federal courts
• Reviewed and compiled Motions for Summary Judgment, appellate Excerpts of Records • Summarized deposition transcripts and voluminous medical records, • Served as office manager; arranging CMC’s and other appearances for attorneys and
maintained office supplies levels Worker’s Rights Clinic, Legal Aid at Work – San Francisco, CA Clinic Counselor, January – April 2017
• Interviewed dozens of clients, in person and over the phone about their legal issues • Researched applicable laws, including FEHA, Title VII, ADEA, etc. and discussed legal
options with supervising attorneys • Prepared and briefed client for his Unemployment Insurance hearing in opposition of his
