UNITED STATES DISTRICT COURT

Transcription

1 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 1 of 28 Page ID #: MARLIN & SALTZMAN, LLP Stanley D. Saltzman, Esq. (SBN 90058) Cody R. Kennedy, Esq. (SBN ) Agoura Road, Suite 210 Agoura Hills, CA Telephone: (818) Facsimile: (818) ssaltzman@marlinsaltzman.com ckennedy@marlinsaltzman.com Attorneys for Plaintiffs and the Class (Counsel continued on next page) UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA MUHAMMED ABDULLAH, et al., as an individual and on behalf of all others similarly situated, v. Plaintiffs, U.S. SECURITY ASSOCIATES, INC., a Corporation, Defendant. Case No. CV PSG (Ex) (Assigned to Hon. Philip S. Gutierrez) DECLARATION OF KENNETH H. YOON IN SUPPORT OF PLAINTIFFS MOTION FOR ATTORNEYS FEES AND COSTS, AWARD OF CLASS REPRESENTATIVES ENHANCEMENT PAYMENTS, AND SETTLEMENT ADMINISTRATION COSTS DECLARATION OF KENNETH H. YOON Case No PSG (Ex)

2 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 2 of 28 Page ID #: Additional Attorneys for Plaintiffs and the Class: PETER M. HART (State Bar No ) LAW OFFICES OF PETER M. HART Wilshire Blvd., Suite 205 Los Angeles, CA Telephone: (310) Facsimile: (509) hartpeter@msn.com KENNETH H. YOON (Bar No ) LAW OFFICES OF KENNETH H. YOON One Wilshire Boulevard, Suite 2200 Los Angeles, California Telephone: (213) Facsimile: (213) kyoon@yoonlaw.com LARRY W. LEE (Bar No ) DIVERSITY LAW GROUP, APC 550 S. Hope Street, Suite 2655 Los Angeles, California Telephone: (213) Facsimile: (213) lwlee@diversitylaw.com DECLARATION OF KENNETH H. YOON Case No PSG (Ex)

3 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 3 of 28 Page ID #: DECLARATION OF KENNETH H. YOON I, Kenneth H. Yoon, declare as follows: 1. I am an individual over the age of 18. I am a California bar-admitted attorney with a private practice. My firm is the Law Offices of Kenneth H. Yoon. I am one of the attorneys of record for Plaintiffs Muhammed Abdullah, Christina Aguilar and William Kimbrough, IV ( Plaintiffs ) and the Class in the instant action. I have personal knowledge of the facts set forth below and if called to testify I could and would do so competently. THE SETTLEMENT IS FAIR 2. I have reviewed the weekly reports provided by the settlement administrator. Based on the preliminary results of the class notice, I maintain the same opinion expressed in support of preliminary approval: the settlement is fair, reasonable, and adequate and is in the best interests of the Class and the Defendant in light of all known facts and circumstances and the expenses and risks of this litigation and inherent in litigation. 3. In addition, several class members have contacted me. None have expressed any intent to submit an objection and none have expressed any negative option of the settlement. ATTORNEY TIME AND EXPENSES ARE REASONABLE 4. As per the Order re: Plaintiffs Motion for Class Certification filed January 11, 2011 (DE 50) my firm is one of the Class Counsel firms on this matter and I am one of the appointed class counsel. During the lengthy history of this litigation, my firm has varied in number of attorneys, from between two and four. Currently, my firm totals three attorneys, myself and two associates. 5. My firm s primary focus is employment law, representing almost exclusively employees. I have handled a number of wage and hour matters, including class actions. I have a practice that encompasses cases in the California Superior Courts and the United States District Courts before all the California Case No. 9-CV-9554-GHK (Ex) JOINT STIPULATION RE DEPOSITION SUBPOENAS TO ABSENT CLASS MEMBERS

4 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 4 of 28 Page ID #: Districts, before the United States Court of Appeals for the Ninth Circuit and before the Court of Appeal for the State of California. My billing rate for work for 2017 is $725 per hour. My historical rates for the past three years have ranged from $650 to the present rate. Based on my experience I know that the present hourly rate of $ per hour is a reasonable hourly rate for this type of litigation. I have been approved at my prior rates and at my 2017 rate in California state courts. 6. Currently associated with my firm during part of the litigation of this matter was Stephanie E. Yasuda. Her involvement in the matter is as detailed in the attached exhibit of contemporaneously maintained time records. I directly supervised Ms. Yasuda s work to ensure the quality of the work, the necessity of the work and to minimize duplication of attorney time. Ms. Yasuda received her J.D. from Loyola Law School, Los Angeles, in 2009 and is admitted to practice in the state of California. Ms. Yasuda received her J.D., cum laude, Order of the Coif, in 2009 from Loyola Law School, Los Angeles, where she graduated in the top ten percent (10%) of her class. She was admitted to practice in California the same year. During law school, she served as an editor of the Public Interest Law Journal and a board member of the Public Interest Law Foundation, and competed as part of Loyola s three-member team in the LAWASIA International Moot Court Competition. She also completed internships with the ACLU of Southern California and the Disability Rights Legal Center. She has been employed with the Law Offices of Kenneth H. Yoon since March She is admitted to practice in the Courts of the State of California, all United States District Courts of California, the United States Court of Appeals for the Ninth Circuit, and the United States Supreme Court. Ms. Yasuda s current billing rate for 2017 is $500 per hour. She has been granted final approval at her 2017 rate by several courts in California. 7. Previously associated with my firm was Linda P. Whitehead. I directly supervised Ms. Whitehead s work to ensure the quality of the work, the necessity of the work and to minimize duplication of attorney time. Ms. Whitehead received Case No. 9-CV-9554-GHK (Ex) JOINT STIPULATION RE DEPOSITION SUBPOENAS TO ABSENT CLASS MEMBERS

5 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 5 of 28 Page ID #: her J.D. from Loyola Law School, Los Angeles, in 2002 and was admitted to the California State Bar that year. 8. During law school, she interned for the Honorable Lourdes Baird, then United States District Court Judge for the Central District of California. She graduated 5th in her class and was Editor-in-Chief of the Loyola of Los Angeles Law Review. Prior to joining my office, Ms. Whitehead clerked for Judge Nora M. Manella and was associated with Irell & Manella LLP and Seyfarth Shaw LLP, two national law firms. Ms. Whitehead has been approved for her past work performed for this firm at the rate of $475 per hour in Villegas v. J.P. Morgan Chase & Co., et al., N.D. Cal. Case No. CV SBA and at the same rate of $475 per hour in De La Cruz et al. v. Abercrombie & Fitch Co. et al., Orange County Superior Court Case No Other attorneys have worked under my supervision and performed work on this matter; some of that attorney time is identified by other firms in this case. 10. My firm has incurred hours in attorney time, which is a corresponding amount of $500, in fees, as set forth in Exhibit A to this declaration. This firm bills time on a daily basis. My firm s billing practices are modeled on my training and experience while working at other law firms, prior to starting my own practice in Though I worked for smaller firms, those firms were comprised of former larger firm partners, and thus my practices mirror a large firm s practices. I anticipate an additional 5 hours of work, corresponding to an additional $3, in fees. Thus, the total hours in this case are and $503, in fees. 11. Time is anticipated based on time to attend the final fairness hearing and post-approval for time as part of class member telephone calls/inquiries, communications with the administrator regarding payment logistics and issues and other post-approval issues. This estimate may be low or high but is in my Case No. 9-CV-9554-GHK (Ex) JOINT STIPULATION RE DEPOSITION SUBPOENAS TO ABSENT CLASS MEMBERS

6 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 6 of 28 Page ID #: experience a reasonable estimate at this point in time. 12. I have incurred total costs in this matter (and only this matter) as set forth in the below chart. This is exclusive of anticipated costs for travel to attend the final fairness hearing. Cost Amount Court Reporter $ Court Services Court Copies FedEx Filing Fees Mileage PACER Public Act Request Costs Parking 266 Postage Printing and Duplication 1, Travel Admit Fees Misc Anticipated Parking TOTAL $4, I review all invoices for reasonableness. I regularly review all charges to make sure they are reasonable. I do not advance unnecessary costs and none of the costs advanced in this case were unnecessary. 14. I kept contemporaneous records of hours spent prosecuting this matter, as did all associates at the firm. Hours logged were and are individually tracked Case No. 9-CV-9554-GHK (Ex) JOINT STIPULATION RE DEPOSITION SUBPOENAS TO ABSENT CLASS MEMBERS

7 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 7 of 28 Page ID #: and recorded for this case. 15. Class counsel undertook this matter solely on a contingent basis, with no guarantee of recovery of fees or even reimbursement of costs and no guarantee as to the potential duration of the litigation. Indeed, my firm has received no compensation for our time spent to date or costs advanced to date. It has been almost one decade since we started this litigation. Some plaintiffs I have agreed to represent on a contingency fee basis, as putative class actions, have proven unsuccessful and in those cases, I have received nothing in fees or for my advanced costs. I declare under penalty of perjury under the laws of the California that the foregoing is true and correct. Executed on this 3rd day of November, 2017, at Los Angeles, California. By: /s/ Kenneth H. Yoon Kenneth H. Yoon Case No. 9-CV-9554-GHK (Ex) JOINT STIPULATION RE DEPOSITION SUBPOENAS TO ABSENT CLASS MEMBERS

8 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 8 of 28 Page ID #:7443

9 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 9 of 28 Page ID #:7444 Abdullah v. U.S. Security Associates, Inc. Fees Date Rate Hrs Amount Description 01/10/2009 KHY $2, Review and revise draft complaint, incl. legal research. 01/15/2009 KHY $1, Research re: defendant and other lawsuits/settlements. 01/28/2009 KHY $ Telephone conference with PMH re: settlement position of defendant. 02/19/2009 KHY $ Review related case notice. 02/20/2009 KHY $ Finalize written discovery to defendant. 02/25/2009 KHY $72.50 Review order to show cause notice. 04/10/2009 KHY $ Review proposed protective order. 04/15/2009 KHY $72.50 Review notice of CMC. 04/18/2009 KHY $1, Review Defendant's responses to first set of written discovery. 04/25/2009 KHY $ Commence review of discovery requests and preparation of responses. 05/18/2009 KHY $ Read and revise draft meet and confer letter to opposing counsel. 07/20/2009 KHY $ Prepare re: client deposition; review changes to belaire-west letter prepared by defendant. 07/21/2009 KHY $72.50 Prepare to co-counsels re: deposition of plaintiff. 07/23/2009 KHY $ Review stipulation re: Belaire-West letter. 07/31/2009 KHY $ Prepare to CPT re: mailing administration; review from CPT re: same. 08/17/2009 KHY $ Telephone conference with PMH re: discovery. 08/21/2009 KHY $ Attend case management conference, including travel time. 08/24/2009 KHY $ Prepare for telephone conference with opposing counsel re: data; telephone conference with opposing counsel re: data; telephone conference with PMH re: same. 08/27/2009 KHY $ Telephone conference R. Boughton re: data sampling size; telephone conference with co-counsel re: same. 08/31/2009 KHY $2, Telephone conference with opposing counsel re: data; telephone conference with client; prepare for client meeting; conference with client re: deposition preparation. 09/01/2009 KHY $4, Defend deposition of Plaintiff, including travel time. 09/02/2009 KHY $ Prepare to MMC re: belaire west draft; prepare to mailing administrator re: same; telephone conference with PMH re: same. 09/03/2009 KHY $ Review s from mailing administrator re: mailer. 09/10/2009 KHY $ Telephone conference with client; prepare right to sue letter and cover letter. 09/11/2009 KHY $ Telephone conference with two members. 09/14/2009 KHY $ Telephone conference with several members; telephone conference with co-counsels re: strategy. 09/15/2009 KHY $ Telephone conference with two members; telephone conference with client.

10 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 10 of 28 Page ID #: /16/2009 KHY $ Conference with MMC re: telephone conferences with class members. 09/30/2009 KHY $1, Review class data; telephone conference with PMH re: same; telephone conference with expert consultant re: same. 10/04/2009 KHY $2, Conference with expert consultant re: data, including travel time. 10/05/2009 KHY $ Telephone conference with PMH re: data and mediation; exchange correspondences via with co-counsels re: same. 10/06/2009 KHY $1, Prepare for mediation; review mediation briefs; telephone conference with PMH re: preparation for mediation. 10/07/2009 KHY $4, Attend mediation, including travel time; conference with PMH re: same. 10/19/2009 KHY $ Review and revise correspondence to opposing counsel re: settlement. 10/21/2009 KHY $1, Telephone conference with PMH re: preparation for hearing; review file in preparation for hearing; review correspondence via from opposing counsel re: stay; telephone conference with PMH re: stay. 10/22/2009 KHY $ Attend hearing on post mediation status conference, including travel time. 10/26/2009 KHY $ Conference with MMC re: meetings with witnesses. 11/03/2009 KHY $ Review and revise FAC; telephone conference with PMH re: same; telephone conference with MMC and PMH re: same. 11/16/2009 KHY $ Commence initial read and review of opposition to amendment; telephone conference with PMH re: same. 11/17/2009 KHY $1, Review and revise related case notice; conference with MMC re: reply brief; conference with LPW re: brief on stay; telephone conference with PMH re: same. 11/20/2009 KHY $ Telephone conference with PMH re: discovery. 12/01/2009 KHY $ Telephone conference with PMH re: hearing and case strategy. 12/14/2009 KHY $ Review ex parte application; telephone conference with PMH re: same; conference with MMC re: same. 12/15/2009 KHY $ Conference with MMC re: hearing. 01/04/2010 KHY $ Prepare correspondence via to co-counsels re: notice of related case. 01/06/2010 KHY $ Exchange correspondence via with co-counsel re: filing date for class cert; telephone conference with pmh; telephone conference with pmh and lwl re: judge strategy. 01/25/2010 KHY $ Review defendant's response to OSC re: remand. 02/20/2010 KHY $ Review scheduling orders of the court; telephone conference with PMH re: same. 02/22/2010 KHY $ Review correspondence via from opposing counsel re: early meeting; prepare correspondence via re: same. 02/23/2010 KHY $ Review correspondence via from opposing counsel re: early meeting; prepare correspondence via to opposing counsel re: same. 02/26/2010 KHY $ Prepare for and attend early meeting. 03/02/2010 KHY $ Prepare stip to continue 90 day rule; prepare correspondence via to opposing counsel re: same; prepare correspondence via to co-counsels re: early meeting.

11 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 11 of 28 Page ID #: /07/2010 KHY $ Prepare correspondence via to opposing counsel re: stipulation continuing briefing. 03/12/2010 KHY $ Prepare to opposing counsel re: joint report; review joint report. 04/02/2010 KHY $ Telephone conference with Ross Boughton re: stay and consolidation, etc. 04/07/2010 KHY $ Telephone conference with opposing counsel re: consolidation, stay. 04/08/2010 KHY $ Telephone conference with PMH re: consolidation and lead counsel; prepare correspondence via re: same. 04/22/2010 KHY $1, Review order from court re: consolidation and lead counsel; telephone conference with L. Banayad re: draft cert. motion; review Morehead case history; prepare correspondence via to PMH re: motion to consolidate and lead counsel. 05/10/2010 KHY $2, Review opposition to stay; telephone conference with PMH re: same; conference with LPW re: same; review and revise stipulation to continue deadlines; telephone conference with PMH re: same; leave message for class member. 05/11/2010 KHY $1, Telephone conference with O. McGee re: stipulation; review status of stipulation; telephone conference with PMH re: same; revise stipulation for local rules; review correspondence via from opposing counsel re: same; conferences with LPW re: joint brief; telephone conference with PMH re: same; review case law re: same. 05/12/2010 KHY $1, Review case file in support of motion for lead status; review data and discovery in case; conference with LPW re: same; telephone conference with PMH re: same; review and revise briefing. 05/18/2010 KHY $ Prepare draft agreement re: Morehead action; conference with PMH re: opposition to lead counsel and lead plaintiff. 05/19/2010 KHY $ Conferences with co-counsels re: Preparation of stipulation, notice, and order for filing. 05/21/2010 KHY $ Telephone conference with client; conference with LPW re: certification motion; telephone conference with PMH re: same. 05/22/2010 KHY $ Prepare draft stipulation of Morehead action; prepare draft correspondence via to opposing counsel re: same. 06/07/2010 KHY $1, Conference with LPW re: certification motion; review draft of same; prepare correspondence via to LPW re: same. 06/09/2010 KHY $1, Prepare correspondence via to co-counsel re: deposition dates for availability; review motion for certification. 06/10/2010 KHY $ Review client declarations and revise; telephone conferences with LWL and PMH re: same; conference with LPW and MMC re: motion for certification. 06/13/2010 KHY $3, Review and revise motion for certification; telephone conference with PMH re: same. 06/16/2010 KHY $ Conference with LPW re: motion for certification. 06/18/2010 KHY $1, Review and revise draft correspondence via to opposing counsel; telephone conference with PMH re: same; prepare correspondence via to LPW re: research assignment 06/21/2010 KHY $ Prepare stipulation and order to opposing counsel re: scheduling briefing and continuance; prepare correspondence via to opposing counsel re: same.

12 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 12 of 28 Page ID #: /22/2010 KHY $ Exchange correspondence via with opposing counsel re: stipulation to continue hearing and briefing schedule; revise same. 07/01/2010 KHY $ Prepare correspondence via to opposing counsel re: deposition of Mr. Abdullah. 07/02/2010 KHY $ Finalize correspondence via to opposing counsel re: depositions. 07/03/2010 KHY $ Telephone conference with one member. 07/08/2010 KHY $3, Conference with client and MMC re: deposition preparation; defend client deposition, including travel time; conference with client re: same. 07/12/2010 KHY $ Exchange correspondence via with co-counsels re: deposition dates. 07/22/2010 KHY $ Prepare correspondence via to opposing counsel to re: deposition. 07/26/2010 KHY $ Telephone conference with opposing counsel re: deposition scheduling; telephone conference with LWL and PMH re: same. 07/30/2010 KHY $3, Prepare for and defend expert consultant deposition; conference with MMC re: discovery responses. 08/02/2010 KHY $ Review draft discovery responses; review correspondence via from opposing counsel re: extension, 08/17/2010 KHY $2, Read and review defendant's opposition to certification; conference with MMC re: declarations re: same; legal research re: on duty meal periods. 08/18/2010 KHY $1, Review opposition and declarations; telephone conference with PMH re: reply; conference with PMH and LPW re: same. 08/19/2010 KHY $3, Review opposition and declarations; conference with PMH, MMC, KAW and LPW re: response. 08/20/2010 KHY $2, Review and read opposition; telephone conference with PMH re: reply; conference with MMC and PMH. 08/23/2010 KHY $1, Legal research re: reply brief; review and revise settlement letter to opposing counsel; telephone conference with PMH re: same. 08/26/2010 KHY $1, Conference with MMC and PMH re: objections to 103 declarations; telephone conference with PMH re: meal certification issues; legal research re: same; legal research re: Boyd trial court pleadings. 08/31/2010 KHY $5, Conference with expert and defend J. Krock deposition, including travel time; telephone conference with PMH re: reply brief; conference with MMC re: evidentiary objections and responses. 09/02/2010 KHY $1, Review response to objections to evidence and objections to defendant's evidence; conference with MMC re: same. 09/15/2010 KHY $ Telephone conference with PMH re: order taking matter under submission and re settlement and re: client communication. 10/06/2010 KHY $ Telephone conference with one member. 10/25/2010 KHY $72.50 Telephone conference with client. 01/11/2011 KHY $72.50 Telephone conference with one putative member. 01/13/2011 KHY $ Telephone conference with PMH re: post certification.

13 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 13 of 28 Page ID #: /14/2011 KHY $ Telephone conference with client; telephone conference with attorney for class member. 01/27/2011 KHY $1, Review petition for review; conference with PMH re: response to same; conference with LPW re: draft opposition. 02/02/2011 KHY $ Review and revise draft opposition to petition for review; conference with LPW re: same. 02/04/2011 KHY $ Review and finalize opposition brief; telephone conference with PMH re: same; conference with LPW re: finalizing brief and filing. 02/09/2011 KHY $ Review draft correspondence via to opposing counsel re: reconsideration meet and confer; review motion for reconsideration. 02/14/2011 KHY $ Conferences with LPW re: research assignment; review correspondence via from LPW re: same. 02/25/2011 KHY $ Telephone conference with PMH re: mediator correspondence; review deadline for appeal. 03/28/2011 KHY $ Review minute order. 06/20/2011 KHY $ Telephone conference with mediator; prepare correspondence via to mediator re: attendance; review correspondence via from KAW re: mediation telephone conference; telephone conference with PMH re: same. 06/30/2011 KHY $ Review mediation briefs; telephone conference with PMH re: mediation numbers. 07/01/2011 KHY $1, Telephone conference with PMH re: mediation statement. 07/20/2011 KHY $1, Review and revise draft correspondence via to opposing counsel re: settlement; telephone conference with PMH re: same. 08/03/2011 KHY $ Review settlement letter from defendant; telephone conference with PMH re: same. 08/04/2011 KHY $1, Telephone conference with PMH re: defendant's settlement position. 08/05/2011 KHY $1, Review correspondence via to opposing counsel re: settlement; telephone conferences with PMH re: same. 08/17/2011 KHY $ Telephone conference with one member. 08/23/2011 KHY $ Attend telephone mediation conference; telephone conference with PMH re: same. 08/25/2011 KHY $ Telephone conference with opposing counsel re: mediation; telephone conference with PMH re: same; prepare draft correspondence via to opposing counsel re: same. 09/09/2011 KHY $ Mediation telephone conference; telephone conference with PMH re: same. 09/13/2011 KHY $1, Telephone conference with PMH re: mediator issues; review draft correspondence via to opposing counsel re: same. 09/20/2011 KHY $ Telephone conference with PMH re: settlement issues. 09/21/2011 KHY $ Review correspondence via from co-counsel re: interested parties; telephone conference with PMH re: same. 10/04/2011 KHY $ Telephone conference with PMH re: Brinker. 10/06/2011 KHY $ Telephone conference with PMH re: settlement hearing and settlement. 10/20/2011 KHY $ Telephone conference with PMH re: mediator selection. 10/26/2011 KHY $ Exchange correspondence via with opposing counsel re: mediation; telephone conference with opposing counsel re: discovery and stay.

14 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 14 of 28 Page ID #: /27/2011 KHY $ Exchange correspondence via with opposing counsel re: mediation. 11/01/2011 KHY $ Telephone conference with PMH re: mediation. 11/04/2011 KHY $ Telephone conference with R. Boughton; telephone conference with PMH re: same. 11/08/2011 KHY $2, Attend Brinker hearing, including travel time; telephone conferences with PMH re: same. 11/14/2011 KHY $ Telephone conference with opposing counsel re: extension; telephone conference with PMH re: mediation. 11/22/2011 KHY $ Telephone conference with PMH re: scheduling and postponing mediation. 11/23/2011 KHY $ Review and revise correspondence via to opposing counsel re: extension; telephone conference with PMH re: same. 04/18/2012 KHY $ Review correspondence via to opposing counsel; telephone conference with PMH re: same. 04/19/2012 KHY $ Telephone conference with PMH re: telephone conference with Mark Rudy. 04/24/2012 KHY $1, Review and revise mediation brief; telephone conferences with PMH re: same; legal research re: same. 04/25/2012 KHY $ Review and revise correspondence via to M. Rudy; telephone conferences with PMH re: same. 04/26/2012 KHY $1, Telephone conference with PMH re: settlement and mediation brief. 04/30/2012 KHY $ Telephone conference with PMH re: mediation. 05/01/2012 KHY $2, Review and revise mediation brief; telephone conference with PMH re: same; legal research re: same. 05/07/2012 KHY $1, Prepare for mediation; telephone conference with PMH re: same. 05/08/2012 KHY $5, Attend mediation, including travel time; conference with PMH and LWL re: same. 05/10/2012 KHY $ Review and revise correspondence via to mediator; telephone conference with PMH re: same. 05/29/2012 KHY $ Telephone conference with mediator and opposing counsel and co-counsel; telephone conference with PMH re: same. 05/30/2012 KHY $ Telephone conference with PMH re: correspondence via to mediator; review and revise correspondence via to mediator; telephone conference with PMH re: A. Healy re: telephone conference with opposing counsel. 06/04/2012 KHY $ Review and revise correspondence via to mediator and opposing counsel; telephone conference with PMH re: same. 07/11/2012 KHY $1, Telephone conference with PMH re: telephone conference with mediator and re: settlement procedure. 07/12/2012 KHY $1, Review recent similar case results; telephone conference with PMH re: correspondence via to mediator and settlement; review correspondence via to opposing counsel. 07/13/2012 KHY $1, Review and revise draft correspondence via to opposing counsel; legal research re: ABM case; telephone conference with PMH re: settlement position; review file. 07/17/2012 KHY $2, Conference with co-counsels re: respondent's brief, including travel time. 07/18/2012 KHY $ Review and revise correspondence via to opposing counsel; telephone conference with

15 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 15 of 28 Page ID #:7450 PMH re: same. 07/24/2012 KHY $ Review motion for extension; prepare correspondence via to opposing counsel re: same. 07/26/2012 KHY $ Telephone conference with PMH re: settlement. 08/20/2012 KHY $ Review correspondence via draft to mediator; telephone conference with PMH re: same. 08/22/2012 KHY $ Review correspondence via from mediator; telephone conference with PMH re: settlement. 09/18/2012 KHY $ Telephone conference with PMH re: research issues. 09/24/2012 KHY $1, Review answering brief; review pleadings re: same. 09/25/2012 KHY $4, Telephone conference with PMH re: answering brief; review answering brief and revise same; review correspondence via from co-counsels re: same. 09/26/2012 KHY $1, Telephone conference with PMH re: answering brief; review answering brief and revise same; review correspondence via from co-counsels re: same. 09/27/2012 KHY $1, Continue review and revisions to answering brief; telephone conferences with PMH re: same. 09/28/2012 KHY $2, Telephone conference with PMH re: answering brief; conference with PMH re: joint review and revisions to answering brief, including travel time; telephone conferences with PMH re: same. 09/29/2012 KHY $1, Review and revise answering brief; telephone conference with PMH re: same. 09/30/2012 KHY $1, Review and revise answering brief; telephone conference with PMH re: same. 10/01/2012 KHY $ Review and revise answering brief; telephone conference with PMH re: same. 10/09/2012 KHY $ Legal research. 11/06/2012 KHY $ Telephone conference with PMH re: settlement issues; review draft correspondence via to opposing counsel. 12/20/2012 KHY $ Review and revise correspondence via to opposing counsel; telephone conference with PMH re: same. 01/29/2013 KHY $ Telephone conference with PMH re: preparation for oral argument. 03/04/2013 KHY $3, Prepare for oral argument; conference with co-counsels re: same. 03/06/2013 KHY $6, Prepare for oral argument. 03/07/2013 KHY $2, Prepare for and attend oral argument, including travel time; telephone conference with co-counsels re: same. 03/13/2013 KHY $1, Telephone conference with PMH re: call to Lett counsels; telephone conference with Lett counsels re: overlap and stay. 03/15/2013 KHY $ Telephone conference with PMH re: related state case. 03/20/2013 KHY $ Review and revise draft correspondence via to related case counsel re: stay; telephone conference with PMH re: same. 03/22/2013 KHY $ Telephone conference with client. 03/29/2013 KHY $ Review and revise draft letter to court; telephone conference with PMH re: same. 04/02/2013 KHY $ Review and revise letter brief to court; telephone conference with PMH re: same. 04/09/2013 KHY $ Review correspondence via from mediator; telephone conference with PMH re: same; review correspondence via from PMH. 04/11/2013 KHY $ Review correspondence via from M. Rudy; telephone conference with PMH re: same;

16 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 16 of 28 Page ID #:7451 prepare correspondence via response to M. Rudy. 05/28/2013 KHY $1, Legal research; telephone conference with PMH re: mediation. 05/31/2013 KHY $ Telephone conference with PMH re: correspondence via to M. Rudy. 06/10/2013 KHY $ Telephone conference with PMH re: preparation for telephone conference with M. Rudy. 06/11/2013 KHY $ Telephone conference with M. Rudy. 07/09/2013 KHY $ Research re: other cases; telephone conference with PMH re: same. 08/09/2013 KHY $ Review and revise correspondence via to other plaintiff counsels; telephone conference with PMH re: same. 09/06/2013 KHY $ Telephone conference with PMH re: related cases. 09/11/2013 KHY $ Conference with PMH re: intervention. 09/13/2013 KHY $ Review correspondence via from co-counsels re: Lepp v. US Security. 09/16/2013 KHY $ Review motion to intervene. 09/17/2013 KHY $ Review and revise draft to opposing counsel. 09/18/2013 KHY $ Review court file from Andrews settlement case. 09/20/2013 KHY $ Telephone conference with PMH re: call with Garza counsel; telephone conference with Garza counsel and T. Hodgkins; telephone conference with PMH and TH re: same. 09/23/2013 KHY $ Review correspondence via from T. Hodgkins re: status conference in Garza. 09/26/2013 KHY $ Review correspondence via from C. Hodgkins; telephone conference with PMH re: same. 10/02/2013 KHY $ Exchange correspondence via with co-counsels re: state court cases. 10/03/2013 KHY $1, Telephone conference with LWL, PMH and T. Hodgkins re: multiple state cases. 10/10/2013 KHY $2, Review and revise motion to intervene; telephone conference with PMH re: same. 10/11/2013 KHY $ Review court filings re: appearance by R. Boughton; telephone conference with PMH re: same and re: status conference report and litigation strategy for explaining to the court. 10/14/2013 KHY $ Telephone conference with PMH re: settlement issues and class contact; exchange correspondence via with co-counsel re: same. 10/18/2013 KHY $ Review and revise draft meet and confer letter to opposing counsel re: lifting stay. 10/22/2013 KHY $ Telephone conference with PMH re: strategy re: intervention; exchange correspondence via with co-counsels re: same. 10/24/2013 KHY $1, Review correspondence via drafted by PMH; telephone conference with PMH re: case management and correspondences via s to other lawyers and strategy. 10/25/2013 KHY $1, Telephone conferences with PMH re: mediation letter; review and revise same; review motion for intervention. 10/28/2013 KHY $1, Review and revise correspondence via draft to plaintiff counsel; review and revise intervention motion. 11/06/2013 KHY $ Review draft meet and confer letter; telephone conference with PMH re: same and re: En Banc filing request. 11/07/2013 KHY $ Review Cardenas motion to intervene. 11/14/2013 KHY $1, Telephone conference with Garza defense counsel; exchange correspondence via with

17 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 17 of 28 Page ID #:7452 co-counsels re: motions and strategy. 11/19/2013 KHY $ Review draft correspondence via to opposing counsel. 11/27/2013 KHY $ Finalize comments to answer to En Banc petition. 12/13/2013 KHY $1, Review motion to intervene and motion to stay reply brief drafts; review opposition; telephone conference with co-counsels re: same; exchange correspondence via with co-counsels re: same; telephone conference with class member attorney. 12/20/2013 KHY $ Telephone conference with PMH re: hearing; review correspondence via from co-counsel re: same; prepare correspondence via to co-counsel re: same. 01/07/2014 KHY $72.50 Review substitution of attorney. 01/15/2014 KHY $ Exchange correspondence via with co-counsels and plaintiff counsel in Cardenas. 01/16/2014 KHY $ Review correspondence via to Cardenas' counsel; telephone conference with PMH re: same. 01/22/2014 KHY $ Review correspondence via exchange between plaintiffs and defendant counsel; telephone conferences with PMH re: same. 01/23/2014 KHY $ Telephone conference with PMH re: settlement s from and to opposing counsel. 01/24/2014 KHY $ Review correspondence via re: mediation. 01/28/2014 KHY $ Review draft correspondence via to opposing counsel re: settlement. 02/21/2014 KHY $ Telephone conference with PMH re: mediation. 02/27/2014 KHY $72.50 Prepare correspondence via to SEY re: research. 04/08/2014 KHY $ Review correspondence via draft to mediator M. Rudy. 04/11/2014 KHY $ Initial review of certification; legal research re: same. 04/14/2014 KHY $1, Review petition for certification; telephone conferences with PMH re: same. 04/15/2014 KHY $2, Review mediation brief; telephone conference with PMH re: same. 04/16/2014 KHY $1, Review letter to mediator; telephone conference with PMH re: same. 04/21/2014 KHY $2, Prepare for mediation; research re: same; telephone conference with PMH re: same. 04/22/2014 KHY $9, Attend mediation; conference with LWL and PMH re: same. 04/23/2014 KHY $ Telephone conference with PMH re: settlement. 04/24/2014 KHY $1, Review and revise draft correspondence via to opposing counsel; telephone conference with PMH re: same. 04/25/2014 KHY $ Review and revise draft correspondence via to mediator; telephone conference with PMH re: same; legal research re: same. 05/01/2014 KHY $ Review correspondence via from mediator; conference with PMH re: same, including travel time. 05/02/2014 KHY $ Review and revise draft correspondence via to mediator; telephone conferences with PMH re: same. 05/06/2014 KHY $ Review and revise correspondence via to mediator; telephone conference with PMH re: same. 05/08/2014 KHY $ Telephone conference with public counsel re: retention; prepare draft language.

18 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 18 of 28 Page ID #: /09/2014 KHY $ Correspondence via with co-counsel re: retention. 05/19/2014 KHY $ Telephone conference with PMH re: other cases. 05/21/2014 KHY $ Review meet and confer letter; telephone conference with PMH re: same and re: related case; review related case filing. 05/30/2014 KHY $ Review draft correspondence to opposing counsel re: meet and confer; review court order. 06/03/2014 KHY $ Legal research re: notice and summary judgment. 06/19/2014 KHY $1, Review notice; prepare correspondence via to co-counsel re: same. 06/20/2014 KHY $1, Review and revise notice; telephone conference with PMH re: same. 06/23/2014 KHY $ Exchange correspondence via with co-counsel re: notice issue and reconsideration. 06/26/2014 KHY $ Review correspondence via from opposing counsel and edits to class notice. 07/01/2014 KHY $ Exchange correspondence via with co-counsels re: strategy on notice and reconsideration. 07/11/2014 KHY $ Telephone conference with PMH re: strategy on notice and reconsideration; review correspondence via re: same from co-counsel. 07/14/2014 KHY $ Review stipulation. 07/17/2014 KHY $ Telephone conference with PMH and T. Hodgkins re: notice and stipulation; research re: same. 07/18/2014 KHY $ Telephone conference with opposing counsel re: settlement; exchange correspondence via with co-counsels re: same; prepare correspondence via to opposing counsel re: same. 07/21/2014 KHY $ Initial review of joint report in Cardenas. 07/24/2014 KHY $ Review draft correspondence via to opposing counsel re: notice. 07/25/2014 KHY $1, Prepare correspondence via to opposing counsel re: class notice; review and revise meet and confer letter to opposing counsel re: consolidation, reconsideration. 07/28/2014 KHY $2, Read and review voluminous correspondence received via from opposing counsel and co-counsels over the weekend; review several draft meet and confer correspondences to opposing counsel; telephone conferences with PMH re: same; review and revise report to court re: related case. 07/31/2014 KHY $ Telephone conference with PMH re: discovery from opposing counsel; review and revise draft correspondence via to opposing counsels re: discovery; prepare correspondence via to opposing counsel re: meet and confer. 08/04/2014 KHY $2, Telephone conference with PMH re: preparation for meet and confer; conference with T. Hodgkins in preparation for same; conference with opposing counsel and Mr. Walsh re: meet and confer on several motions, motion to consolidate, motion to stay, motion for summary judgment/adjudication, etc.; telephone conference with PMH and t. Hodgkins re: same; telephone conference with PMH re: same. 08/05/2014 KHY $1, Telephone conference with PMH re: strategy on how to deal with Mr. Walsh and yesterday's meet and confer in light of court order. 08/07/2014 KHY $ Review correspondence via from Mr. Walsh re: meet and confer. 08/08/2014 KHY $ Prepare correspondence via to opposing counsel re: settlement status; review changes to settlement agreement; review and revise same; prepare correspondence via to opposing

19 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 19 of 28 Page ID #:7454 counsel re: same. 08/12/2014 KHY $1, Review and revise draft correspondence via to opposing counsel and related case plaintiff counsel; telephone conference with PMH re: same. 08/13/2014 KHY $2, Conference with PMH and T. Hodgkins re: motion for reconsideration, including travel time. 08/15/2014 KHY $ Finalize correspondence to opposing counsel re: discovery; telephone conference with PMH re: same; review correspondence via from opposing counsel re: same. 08/18/2014 KHY $ Telephone conference with PMH re: production of defendant and strategy; exchange correspondence via with co-counsel re: reconsideration motion. 08/19/2014 KHY $1, Exchange correspondence via with co-counsels re: reconsideration motion; telephone conference with PMH re: reconsideration motion and strategy. 08/20/2014 KHY $ Legal research re: rest period certification. 08/25/2014 KHY $1, Telephone conference with PMH re: reconsideration motion; review and revise same. 08/28/2014 KHY $ Telephone conference with PMH re: administrator; prepare correspondence via to administrator re: notice administration and enclosing all document necessary for same and instructions. 09/04/2014 KHY $ Final review of motion for reconsideration; telephone conference with T. Hodgkins re: same. 09/22/2014 KHY $1, Review and revise reply to reconsideration; telephone conference with PMH re: same; exchange correspondence via with co-counsels re: same. 09/23/2014 KHY $ Telephone conference with PMH re: reconsideration argument. 10/07/2014 KHY $ Telephone conferences with PMH re: co-counsel. 10/20/2014 KHY $ Review correspondence via from co-counsel re: discovery issues; prepare correspondence via to co-counsel re: same and re: timing. 10/30/2014 KHY $1, Review order; conference with PMH re: same; telephone conference with PMH re: same. 10/31/2014 KHY $2, Telephone conferences with PMH re: order on reconsideration and strategy; review order re: status conference; telephone conference with PMH re: same. 11/03/2014 KHY $ Review order; telephone conference with PMH re: same. 11/04/2014 KHY $2, Telephone conference with PMH re: telephone conference with Walsh and Sher; telephone conference with Walsh re: management; telephone conference with PMH re: same; prepare correspondence via to Sher re: scheduling call. 11/05/2014 KHY $2, Telephone conference with PMH re: telephone conference with opposing counsel and Leal-Cardenas' counsel; telephone conference with opposing counsels and PMH re: status conference issues; telephone conference with PMH re: same; review case file in preparation of same. 11/06/2014 KHY $ Telephone conference with PMH re: strategy for hearing and new counsel. 11/11/2014 KHY $ Telephone conference with PMH re: preparation for telephone conference with opposing counsel; telephone conference with opposing counsel re: meet and confer; telephone conference with PMH re: same; prepare correspondence via to PMH re: same. 11/13/2014 KHY $ Telephone conferences with PMH re: telephone conferences with other counsels and strategy re:

20 Case 2:09-cv PSG-E Document Filed 11/03/17 Page 20 of 28 Page ID #:7455 agreements; review draft correspondence via re: same; prepare correspondence via to M. Walsh re: same. 11/14/2014 KHY $ Telephone conference with Walsh; telephone conference with PMH re: same. 11/17/2014 KHY $1, Telephone conference with PMH re: conference call; telephone conference with PMH re: same; exchange correspondence via with co-counsel re: same. 11/18/2014 KHY $1, Telephone conference with PMH re: strategy; telephone conference with S. Salzman and PMH re: same. 11/24/2014 KHY $3, Conference with PMH re: hearing; conference with S. Saltzman and PMH re: same; attend hearing, including travel time; conference with co-counsel and opposing counsel re: discovery issues; conference with PMH re: same. 11/25/2014 KHY $ Telephone conference with PMH re: hearing and strategy. 01/02/2015 KHY $ Telephone conference with PMH re: settlement; review correspondence via between co-counsels re: same. 01/09/2015 KHY $ Telephone conference with PMH re: settlement; review correspondence via from co-counsels and mediator office re: same. 01/12/2015 KHY $ Telephone conference with PMH re: mediation strategy; review correspondence via from Walsh and S. Saltzman re: amended complaint. 01/21/2015 KHY $ Telephone conference with PMH re: mediation issues; review correspondence via between counsel and mediator. 01/30/2015 KHY $ Telephone conference with PMH re: mediation. 03/06/2015 KHY $ Telephone conference with PMH. 03/19/2015 KHY $ Telephone conference with PMH re: preparation for meeting. 03/20/2015 KHY $2, Prepare for meeting and attend meeting with co-counsels re: discovery strategy. 03/25/2015 KHY $ Telephone conference with lawyer with other case against us security requesting information/update. 03/27/2015 KHY $ Telephone conference with client. 04/29/2015 KHY $ Review joint report. 06/23/2015 KHY $ Telephone conference with M. Walsh; prepare correspondence via to co-counsel re: same; telephone conference with PMH re: same; telephone conference with M. Walsh and PMH. 07/06/2015 KHY $ Telephone conference with PMH re: results of hearing. 07/09/2015 KHY $ Telephone conference with PMH re: hearing. 07/31/2015 KHY $ Telephone conference with PMH re: case. 08/03/2015 KHY $ Telephone conference with PMH re: trial and discovery preparation. 08/26/2015 KHY $1, Review data; prepare correspondence via to PMH re: same. 08/28/2015 KHY $ Telephone conference with one caller. 09/01/2015 KHY $72.50 Review correspondence via from PMH. 09/02/2015 KHY $ Telephone conference with one class member; telephone conference with S. Joseph at Marlin & Saltzman re: caller logistics.