SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN LUIS OBISPO CIVIL COURT OPERATIONS UNLIMITED

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1 0 0 Abbas Kazerounian, Esq. (SBN: 0) ak@kazlg.com Matthew M. Loker, Esq. (SBN: ) ml@kazlg.com 0 East Grand Avenue, Suite 0 Arroyo Grande, CA 0 Telephone: (00) 00-0 Facsimile: (00) 0- HYDE & SWIGART Joshua B. Swigart, Esq. (SBN: ) josh@westcoastlitigation.com Camino Del Rio South, Suite 0 San Diego, CA 0 Telephone: () -0 Facsimile: () -0 Attorneys for Plaintiff, Rosa Moreno-Peralta SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN LUIS OBISPO CIVIL COURT OPERATIONS UNLIMITED ROSA MORENO-PERALTA, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, Plaintiff, v. TRS RECOVERY SERVICES, INC.; AND, DOES -0, INCLUSIVE, Defendant. Case No.: CV-0 DECLARATION OF ABBAS KAZEROUNIAN IN SUPPORT OF PLAINTIFF ROSA MORENO- PERALTA S MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT DATE: October, 0 TIME: :00 a.m. DPT: HON. BARRY T. LABARBERA ELECTRONICALLY FILED //0 0: AM Case # CV-0 Moreno-Peralta v. TRS Recovery Services, Inc.., et al.

2 0 0 DECLARATION OF ABBAS KAZEROUNIAN, ESQ. I, ABBAS KAZEROUNIAN declare:. I am one of the attorneys for the Plaintiff ROSA MORENO-PERALTA ( Moreno-Peralta ) in this action.. I submit this declaration in support of the Motion for Preliminary Approval of the Class Action Settlement in the action against Defendant TRS RECOVERY SERVICES, INC. ( TRS ).. I am licensed to practice law before all California Federal Courts; and, all California State Courts.. If called as a witness, I would competently testify to the matters herein from personal knowledge.. The declaration is based upon my personal knowledge, except where expressly noted otherwise.. I incorporate by reference the discussion regarding the adequacy of this settlement from the Declaration of Matthew M. Loker. CLASS COUNSEL S EXPERIENCE. Kazerouni Law Group, APC; and, Hyde & Swigart seek to be confirmed as class counsel for purposes of this action and proceeding with the settlement.. Since my admission to the California bar in 00, I have been engaged exclusively in the area of consumer rights litigation, primarily in the area of fair debt collections, the defense of debt collection lawsuits, class action litigation under the Telephone Consumer Protection Act, California s invasion of privacy statutes, under Penal Code 0 et seq. and California s unfair business statutes under Cal. Civ. Code 00 et seq. and 00 et seq.. My firm, Kazerouni Law Group, APC, in which I am a principal, has litigated over 000 individual consumer cases and over 00 consumer class actions. These class actions were litigated in federal courts in Arizona, California, Washington, Case # CV-0 of Moreno-Peralta v. TRS, et al.

3 0 0 Ohio, Nevada, New Jersey, New York, Minnesota, Missouri, Tennessee, Illinois and Texas, as well as California State Courts. Approximately % percent of my practice concerns consumer litigation in general. My firm has six offices in Orange County, San Luis Obispo, Phoenix, Dallas, Las Vegas, and Oakland. Kazerouni Law Group, APC has extensive experience in consumer class actions and other complex litigation. My firm has a history of aggressive, successful prosecution of consumer class actions. S CONSUMER RELATED EXPERIENCE AND RESULTS 0. Kazerouni Law Group, APC has extensive experience in other consumer related issues, including the Telephone Consumer Protection Act, the Fair Debt Collection Practices Act and other related consumer statutes. A brief summary of a non-exhaustive list of notable published decisions are as follows: a. Franklin v. Wells Fargo, N.A., No. -cv--mma-bgs (S.D. Cal.) (approved for $,0,); b. Knell v. FIA Card Services, N.A., -cv- AJB (WVG) (S.D. Cal.) (California class action settlement under Penal Code et seq., for claims of invasion of privacy. Settlement resulted in a common fund in the amount of $,0,000; finally approved by Court; c. Knutson v. Schwan s Home Service, Inc. et al., :-cv-00-ajb-dhb (S.D. Cal.) (finally approved for $,,0); d. Zaw v. Nelnet, Inc., C - RS (N.D. Cal.) (California class action settlement under Penal Code et seq., for claims of invasion of privacy. Settlement resulted in a common fund in the amount of $,,0.00; finally approved on November, 0; Case # CV-0 of Moreno-Peralta v. TRS, et al.

4 0 0 e. Malta, et al. v. Wells Fargo Home Mortgage, et al., 0-CV-0 IEG (BLM) (Served as co-lead counsel for a settlement class of borrowers in connection with residential or automotive loans and violations of the TCPA in attempts to collect on those accounts; obtained a common settlement fund in the amount of $,00,000; final approval in 0); f. Conner v. JPMorgan Chase Bank, et al., 0-CV--DMS (BGS) (S.D. Cal.) (finally approved for $,,); g. In Re: Midland Credit Management, Inc., Telephone Consumer Protection Act Litigation, -md- MMA (MDD) (S.D. Cal.) (Counsel for a Plaintiff in the lead action, prior to the action being recategorized through the multi-district litigation process; preliminarily approved for $,000,000); h. In Re: Portfolio Recovery Associates, LLC Telephone Consumer Protection Act Litigation, -md-0-jah (BGS) (Counsel for a Plaintiff in the lead action, prior to the action being re-categorized through the multi-district litigation process; still actively involved in the MDL litigation and settlement process; preliminarily approved for $,000,000); i. Arthur v. SLM Corporation, 0-CV-00 JLR (W.D. Wash.) (nationwide settlement achieving the then-largest monetary settlement in the history of the TCPA: $.; final approval granted in 0) j. Lo v. Oxnard European Motors, LLC, et al., -CV-00-JLS-MDD (S.D. Cal.) (achieving one of the highest class member payouts in a TCPA action of $,.; final approval granted in 0); k. Sarabri v. Weltman, Weinberg & Reis Co., L.P.A., 0-0-AJB-NLS (S.D. Cal.) (approved as co-lead counsel and worked to obtain a national Case # CV-0 of Moreno-Peralta v. TRS, et al.

5 0 0 TCPA class settlement where claiming class members each received payment in the amount of $0.00; final approval granted in 0); l. Barani v. Wells Fargo Bank, N.A., -CV-0-GPC-KSC (S.D. Cal.) (Class action settlement under the TCPA for the sending of unauthorized text messages to non-account holders in connection to wire transfers; finally approved for more than $,000,000) m. Sherman v. Yahoo!, Inc., 0 U.S. Dist. LEXIS ; -CV-00- GPC-WVG (S.D. Cal.) (TCPA class action where Defendant s motion for summary judgment was denied holding that a single call or text message with the use of an ATDS may be actionable under the TCPA). n. Olney v. Progressive Casualty Insurance Company, 0 U.S. Dist. LEXIS (S.D. Cal.); -CV-0-GPC-NLS (Defendant s motion to dismiss or in the alternative to strike the class allegations was denied finding that debt collection calls were not exempt from coverage under the TCPA); o. Iniguez v. The CBE Group, Inc., 0 U.S. Dist. LEXIS 0 (E.D. Cal.); -CV-00-JAM-AC (the court denying Defendant s motion to dismiss and to strike class allegations holding that the TCPA applies to any call made to a cellular telephone with an ATDS); p. Mills v. HSBC Bank Nevada, N.A., Case No. -CV-000-SI (N.D. Cal.) (TCPA class action, settled and finally approved for $,,000); q. In Re Jiffy Lube International, Inc., MDL No. [Finally approved for $,000,000.00]; r. Sherman v. Kaiser Foundation Health Plan, Inc., -CV-0-JAH (JMA) (S.D. Cal.) (Finally approved for $,0,000); Case # CV-0 of Moreno-Peralta v. TRS, et al.

6 0 0 s. Hoffman v. Bank of America, -cv- JAH (DHB) (S.D. Cal.) (California class action settlement under Penal Code et seq., for claims of invasion of privacy. Settlement resulted in a common fund in the amount of $,00,000; finally approved by Court; t. Couser v. Comenity Bank, No. (S.D. Cal.) (finally approved TCPA class action with common fund of $,,000); u. Lemieux v. EZ Lube, Inc., -cv- BAS (JLB) (S.D. Cal.) (Class settlement finally for $, approved and Kazerouni Law Group, APC appointed as class counsel) v. Newman v. Americredit Financial Services, Inc., -cv-0 DMS (BLM) (S.D. Cal.) (TCPA Class settlement in the amount of $,00, finally approved). w. Martin v. Wells Fargo Bank, N.A., -CV-000-SI (N.D. Cal.); x. Heinrichs v. Wells Fargo Bank, N.A., -CV-0-WHA (N.D. Cal.); y. Newman v. ER Solutions, Inc., -CV-0 H (BGS); z. Ridley v. Union Bank, N.A., -CV- DMS (NLS) (S.D. Cal.); aa. Ryabyshchuk v. Citibank (South Dakota) N.A., et al, -CV--IEG (WVG); bb. Olney v. Job.com, Inc. et al., No. -cv-0-ljo-sko (E.D. Cal.); cc. Montoya v. SLM Corp. et al., No. :-cv-00 (N.D. Cal.); dd. Rose v. Bank of Am. Corp., No. -cv-00-ejd (N.D. Cal.) (finally approved for $,000,000); ee. Abdeljalil v GE Capital Retail Bank, -cv-00 JAH MDD (S.D. Cal.) (Class Certification granted and preliminarily approved for $,000,000); ff. Barrett v. Wesley Financial Group, LLC, -cv-00-lab-ksc (S.D. Cal.) (Class certification granted); Case # CV-0 of Moreno-Peralta v. TRS, et al.

7 0 0 gg. Gehrich v. Chase Bank, N.A., -cv-0 (N.D. Cal.) (finally approved for $,000,000); hh. Mount v. Wells Fargo Bank, N.A., BC (Sup. Ct. Los Angeles) (finally approved for $,00,000); ii. Maxin v. RHG & Company, Inc., -cv- JLS (BLM) (S.D. Cal.) (Supplement Misrepresentation class action preliminarily approved on February, 0); jj. McPolin v. Credit Service of Logan, -cv- BSJ (Utah District Court) (FDCPA class action preliminarily approved on February, 0); kk. Burkhammer v. Allied Interstate, LLC, cv- (Sup. Ct. San Luis Obispo) (RFDCPA class action preliminarily approved on May, 0); and, ll. Caldera v. Am. Med. Collection Agency, 0 U.S. Dist. LEXIS (C.D. Cal. June, 0) (Order certifying nationwide TCPA class action). ADDITIONAL RELEVANT TRAINING, SPEAKING/TEACHING ENGAGEMENTS AND ASSOCIATIONS. I have undergone extensive training in the area of consumer law. The following is a list of recent training conferences I attended: a. Four-day National Consumer Law Center Conference; Nashville, TN 00; b. Three-day National Consumer Law Center Conference; Portland, OR - 00; c. Three-day National Consumer Law Center Conference; San Diego, CA - 00; Case # CV-0 of Moreno-Peralta v. TRS, et al.

8 0 0 d. Three-day National Consumer Law Center Conference; Seattle, WA - 0; e. Three-day CAALA Conference; Las Vegas, NV 00; f. Three-day CAALA Conference; Las Vegas, NV 0; g. Three-day CAALA Conference; Las Vegas, NV 0; h. Speaker for webinar re Fist Look at the FCC s TCPA Declaratory Rulings; July 0; i. Speaker at the ABA National Conference, Business Litigation Section; Trends in Consumer Litigation; San Francisco, CA 0; and j. Speaker at the ABA TCPA National Webinar (Consumer Protection, Privacy & Information Security, Private Advertising Litigation, and Media & Technology Committees) September 0. k. Speaker at the 0 ACA Conference in November 0. l. January 0, speaker ABA National Conference regarding Consumer Financial Service Committee on Impact of FCC s Declaratory Ruling on the Telephone Consumer Protection Act. m. September 0, speaker at the ACI Conference in Dallas - The Borrower's Perspective: Insight From The Plaintiffs' Bar and Consumer Advocates. n. September 0, speaker at the Annual Consumer Financial Services Conference - TCPA Panel o. June 0, speaker at Consumer Attorneys of California Tahoe Seminar, Hot Topics in Litigation.. As one of the main plaintiff litigators of consumer rights cases in Southern California, I have been requested to and have made regular presentations to community organizations regarding debt collection laws and consumer rights. These organizations include Whittier Law School, Iranian American Bar Case # CV-0 of Moreno-Peralta v. TRS, et al.

9 0 0 Association, Trinity School of Law and Chapman Law School, University of Southern California, Irvine, and California Western School of Law. I was the principle anchor on Time Television Broadcasting every Monday night, as a consultant on consumer law for over a year in 0.. I am an adjunct professor at California Western School of Law where I teach a three-credit course in consumer law.. I have been named Rising Star by San Diego Daily Tribune in 0, and Rising Star in Super Lawyers Magazine in 0, 0 and 0. I have been nominated for Rising Star in Super Lawyers Magazine in 0. I have also been listed on The National Trial Lawyers Top 0 Under 0 in 0.. I was a panelist in a webinar, ABA Telephonic Brown Bag re: TCPA, on August, 0.. I lectured in Class Action Trends at the CAOC 0 Conference in San Francisco.. In January of 0, I spoke on the impact of the Federal Communications Commission's 0 Declaratory Ruling on TCPA litigation at the ABA National Convention in Salt Lake City, Utah.. I am a member in good standing of the following local and national associations: a. National Association of Consumer Advocates; b. Federal Bar Association; c. American Association for Justice; d. Orange County Bar Association; e. California Attorneys Association of Los Angeles; f. Iranian American Bar Association (President for 00 and 00); g. Consumer Attorneys of California (Member of Board of Governors). Case # CV-0 of Moreno-Peralta v. TRS, et al.

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Case 1:15-cv-01058-TWT Document 70-8 Filed 07/24/17 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION FREDERICK LUSTER, on behalf of himself and all