UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Transcription

1 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 Hyde & Swigart David J. McGlothlin, Esq. (SBN: ) david@westcoastlitigation.com Joshua B. Swigart, Esq. (SBN: ) josh@westcoastlitigation.com Camino Del Rio South, Suite 0 San Diego, CA 0 Telephone: () -0 Facsimile: () -0 ABBAS KAZEROUNIAN (SBN 0) Kazerouni Law Group, APC Fischer Avenue, Unit D Costa Mesa, CA Telephone: (00) 00-0 Facsimile: (00) 0- ak@kazlg.com Attorneys for Plaintiffs UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 0 GAIL MEDEIROS, et al., v. Plaintiffs, HSBC CARD SERVICES INC., et al., Defendants. TERRY FANNING, et al., v. Plaintiffs HSBC CARD SERVICES INC., et al., Defendants. STEFAN O. LINDGREN, vs. Plaintiffs, HSBC CARD & RETAIL SERVICES, INC., et al., Defendants. Case No. :-cv-00 JVS (AFMx) Case No. -CV-00-JVS-RNB Relates to: Medeiros, Fanning and Lindgren DECLARATION OF ATTORNEY ABBAS KAZEROUNIAN IN SUPPORT OF PLAINTIFF S MOTION FOR AWARD OF ATTORNEYS FEES, LITIGATION EXPENSES, AND INCENTIVE AWARDS TO NAMED PLAINTIFFS CASE NO. :-cv-00 JVS (AFMx)

2 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 0 I, Abbas Kazerounian, declare as follows:. I am one of the attorneys for the plaintiffs in this action, Gail Medeiros, Tracy Bomberger, Julie Pulatie, and Peter Morrissey ( Plaintiffs I am over the age of and am fully competent to make this declaration. I was admitted to the State Bar of California in 00 and have been a member in good standing ever since that time. I have litigated cases in both state and federal courts in California, Washington, Nevada, Arizona, Arkansas, New York, New Jersey, Colorado, Tennessee, Ohio, Florida, Illinois and Texas. I am admitted in every federal district in California and have handled federal litigation in the federal districts of California. I am also admitted to the state bars of Texas, Illinois, Washington, Michigan, District of Columbia, the Ninth Circuit Court of Appeals, the Eighth Circuit Court of Appeals, and the Supreme Court of the United States.. 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 submit this declaration in support of the Plaintiffs motion for fees and costs and final approval of class action settlement.. This action, which was originally filed on July, 0, was taken on a contingency fee basis.. I have been preliminarily approved as Class Counsel in this matter.. I have incurred. hours in connection with this action, which time records were carefully reviewed. Specifically, I have incurred hours reviewing documents, analyzing data produced by Defendant, communicating with opposing counsel, communicating with co-counsel on related matters, preparing for hearings, preparing for and participating in depositions, motion practice, and a significant amount of time participating in several mediations. CASE NO. :-cv-00 JVS (AFMx)

3 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 0. I am not seeking recovery of fees for hours incurred by paralegals working at Kazerouni Law Group on this action.. I believe that the Parties are fully apprised of the relative strengths and weaknesses of each other s claims and defenses and the potential risks to each party of pursuing further litigation in this matter, especially following mediation.. I continue to be unaware of any conflict of interest between Plaintiffs and any settlement class member or between Plaintiffs and Plaintiffs attorneys. CLASS COUNSEL S EXPERIENCE 0. Since my admission to the State Bar of California 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 pursuant to Penal Code 0, et seq., and false advertising actions concerning consumer products.. The hourly rate that I am seeking in this action is $0, which I believe is reasonable.. Recently, I was approved for an hourly rate of $0 in Oxina v. Lands End, Inc., Case No. :-cv-0-mma-nls (United States District Court, Southern District of California; Dec., 0) and Abdeljalil v. GE Capital Retail Bank, No. :-cv-00-jah-mdd (S.D. Cal. Dec., 0).. I was previously approved for an hourly rate of $ in Mount v. Wells Fargo Bank, N.A., Case No. B0 (Court of Appeal of the State of California, Second Appellate District; Feb. 0, 0). Before that, I was approved for an hourly rate of $ in Sherman v. Kaiser Foundation Health Plan, Inc. :- cv-00-jah-jma, Dkt. No. (May, 0).. My firm, Kazerouni Law Group, APC, in which I am a principal, has litigated over 000 cases in the past eight years. My firm has six offices in Orange CASE NO. :-cv-00 JVS (AFMx)

4 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 0 County, California, Oakland, California, San Luis Obispo, California, Phoenix, Arizona, Las Vegas, Nevada, and Dallas, Texas. 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, Approximately % percent of my practice concerns consumer litigation in general. KAZEROUNI LAW GROUP, APC S CONSUMER RELATED EXPERIENCE AND RESULTS. A brief summary of a non-inclusive list of notable published decisions are as follows: a. 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); b. Olney v. Progressive Casualty Insurance Company, -CV-0-GPC- NLS, 0 U.S. Dist. LEXIS (S.D. Cal.) (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); c. Iniguez v. The CBE Group, Inc., 0 U.S. Dist. LEXIS 0 (E.D. Cal.); -CV-00-JAM-AC (The court denied 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); d. Stemple v. QC Holdings, Inc., No. -cv-0-bas (WVG), 0 U.S. Dist. LEXIS (S.D. Cal. Sep., 0) (order denying defendant s motion for reconsideration of class certification under the TCPA); e. Chen v. Allstate Ins. Co., F.d (th Cir. 0) (order affirming decision finding unaccepted offer of judgment under Fed. R. Civ. P. did not moot the plaintiff s individual TCPA claims). CASE NO. :-cv-00 JVS (AFMx)

5 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: I have filed and litigated numerous consumer class actions over the last several years, including but not limited to the following, which I am or have been personally involved in: a. Lemieux v. EZ Lube, LLC, et al., -CV-0-JLS-WYG (S.D. Cal.) (Served as co-lead counsel; finally approved on December, 0); b. 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 granted in 0); c. Conner v. JPMorgan Chase Bank, et al., 0-CV- DMS (BGS) (S.D. Cal.) (finally approved $,,); d. 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; finally approved for $,000,000); e. 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 recategorized through the multidistrict litigation process; preliminarily approved); f. 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 concerning calls to cellular telephone at the time: $. million; final approval granted in 0); g. 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 $,. per claimant; final approval granted in 0); CASE NO. :-cv-00 JVS (AFMx)

6 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 0 h. 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 TCPA class settlement where claiming class members each received payment in the amount of $0.00 per claimant; final approval granted in 0); i. Barani v. Wells Fargo Bank, N.A., -CV-0-GPC (KSC) (S.D. Cal.) (Co-lead class counsel in a settlement under the TCPA for the sending of unauthorized text messages to non-account holders in connection to wire transfers; finally approved on March, 0 for over $,000,000); j. Mills v. HSBC Bank Nevada, N.A., Case No. -CV-000-SI (N.D. Cal.) (Finally approved for $,,000); k. Martin v. Wells Fargo Bank, N.A., -CV-000-SI (N.D. Cal.); l. Heinrichs v. Wells Fargo Bank, N.A., -CV-0-WHA (N.D. Cal.); m. Newman v. ER Solutions, Inc., -CV-0H (BGS); n. In Re Jiffy Lube International, Inc., MDL No. (Finally approved for $,000,000.00); o. Jaber v. NASCAR, -CV- DMS (WVG) (S.D. Cal.); p. Ridley v. Union Bank, N.A., -CV- DMS (NLS) (S.D. Cal.); q. Ryabyshchuk v. Citibank (South Dakota) N.A., et al, -CV--IEG (WVG); r. Sherman v. Kaiser Foundation Health Plan, Inc., -CV-0-JAH (JMA) (S.D. Cal.) (Settled for $,0,000 and finally approved on May, 0; served as co-lead counsel); s. Rivera v. Nuvell Credit Company LLC, -CV-00-TJH-OP (E.D. Cal.); t. Karayan v. Gamestop Corp., :-CV-0-P (N.D. Texas); u. Foote v. Credit One Bank, N.A. et al., -cv-00-mwf-pla (C.D. Cal.); CASE NO. :-cv-00 JVS (AFMx)

7 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 0 v. Webb v. Healthcare Revenue Recovery Group, -cv-00 RS (N.D. Cal.); w. Knell, et al. v. FIA Card Services, N.A., -CV-0-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 in August, 0); x. Hoffman v. Bank of America Corporation, -CV-00-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 on November, 0 and served as co-lead counsel); y. Couser v. Comenity Bank, -cv-0-mma-bgs (S.D. Cal. Oc., 0) (Finally approved for $,,000 on May, 0 as served as colead counsel); z. Couser v. Apria Healthcare, Inc. et al., -cv-000-jvs-rnb (C.D. Cal. Oct., 0) (Finally approved on March, 0 and served as co-lead counsel); aa. Rose v. Bank of America Corporation et al., -cv-000-ejd (N.D. Cal.) (Finally approved for $,000,000 in 0); bb. Newman v. AmeriCredit Financial Services, -cv-00-dms-blm (S.D. Cal.) (finally approving TCPA settlement for over $,00,000 on March, 0); cc. Fox v. Asset Acceptance, LLC, -cv-00-gw-ffm (C.D. Cal. July, 0) (finally approved TCPA class action for $,000,000; $00,000 cash and $00,000 debt relief); dd. Barrett v. Wesley Financial Group, LLC, -cv-00-lab-ksc (S.D. Cal.) (Class certification granted); and, CASE NO. :-cv-00 JVS (AFMx)

8 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 0 ee. Gehrich v. Chase Bank, N.A., -cv-0 (N.D. Cal.) (finally approved for $,000,000); ff. Macias v. Water & Power Community Credit Union, BC (Los Angeles Superior Court) (Class certification granted under the Rosenthal Fair Debt Collection Practices Act; class action settlement finally approved on April, 0); gg. Mount v. Wells Fargo Bank, N.A., BC (Sup. Ct. Los Angeles) (finally approved for $,00,000); hh. Oxina v. Lands End, Inc., :-cv-0-mma-nls (S.D. Cal. 0) (finally approved settlement under California Made in the USA statute); ii. LaPuebla v. BirchBox, Inc., :-cv-00-ben-bgs (S.D. Cal. 0) (finally approved settlement in unlawful auto-renewal action); jj. Medeiros v. HSBC Bank Nevada, N.A., :-cv-0-jls-mdd (S.D.Cal. 0) (preliminarily approved action under the California Invasion of Privacy Act, Penal Code, et seq.); kk. Stemple v. QC Holdings, Inc., -cv-0-bas-wvg (S.D. Cal. Nov., 0) (finally approved for $,00,000); ll. Abdeljalil v. GE Capital Retail Bank, -cv-00 JAH MDD (S.D. al.) (Class Certification granted and finally approved for $,000,000).. Many of the cases listed above, which have settled, resulted in the creation of combined common funds and/or distribution to class member in the hundreds of millions of dollars. The outstanding results mentioned above are a direct result of the diligence and tenacity shown by Kazerouni Law Group, APC and myself, in successfully prosecuting complex class actions.. I argued before the Ninth Circuit Court of Appeals in the case of Knutson v. Sirius XM Radio, No. -0 (th Cir. 0) as co-lead counsel, which resulted in an order in favor of my client. Also, on December, 0, I argued before the Ninth Circuit Court of Appeals in the case of Marks v. CASE NO. :-cv-00 JVS (AFMx)

9 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 0 Crunch San Diego, LLC, No. -. ADDITIONAL RELEVANT TRAINING, SPEAKING/TEACHING ENGAGEMENTS AND ASSOCIATIONS. I am an adjunct professor at California Western School of Law where I teach a three-credit course in consumer law. 0. I have undergone extensive training in the area of consumer law and the Telephone Consumer Protection Act. 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; d. Three-day National Consumer Law Center Conference; Seattle, WA -0; e. National Consumer Law Center Conference in 0; f. National Consumer Law Center Conference in 0; g. National Consumer Law Center Conference in 0; h. National Consumer Law Center Conference in 0; i. Three-day CAALA Conference; Las Vegas, NV 00; j. Three-day CAALA Conference; Las Vegas, NV 0; k. Three-day CAALA Conference; Las Vegas, NV 0; l. Three-day CAALA Conference; Las Vegas, NV 0; m. Three-day CAOC Conference 0 and 0; n. Speaker at ABA National Conference, Business Litigation Section; Trends in Consumer Litigation; San Francisco, CA 0; o. Speaker at the ABA TCPA National Webinar (Consumer Protection, Privacy & Information Security, Private Advertising Litigation, and Media & Technology Committees) September 0; CASE NO. :-cv-00 JVS (AFMx)

10 Case :-cv-00-jvs-rnb Document - Filed 0// Page 0 of Page ID #: 0 0 p. Spoke at the 0 ACA Conference in November 0; q. Speaker at ACI Conference in Dallas, TX in September of 0 concerning The Borrower's Perspective: Insight From The Plaintiffs' Bar and Consumer Advocates; r. Speaker on TCPA panel in September of 0 at the Annual Consumer Financial Services Conference; and, s. Due to speak at the 0 CAOC Conference in November of 0.. As one of the main plaintiff litigators of consumer rights cases in the Central District of California, I have been requested to and have made regular presentations to community organizations regarding debt collection laws and consumer rights, including the Telephone Consumer Protection Act ( TCPA ). These organizations include Whittier Law School, Iranian American Bar Association, Trinity School of Law and Chapman Law School, University of California, Irvine, and California Western School of Law.. I was the principle anchor on Time Television Broadcasting every Thursday night as an expert on consumer law generally, and the TCPA specifically, between 0 and 0.. I was named Rising Star by San Diego Daily Tribune in 0, and Rising Star in Super Lawyers Magazine in 0, 0 and 0. I was named a Super Lawyer by Super Lawyers Magazine in 0.. I lectured in Class Action Trends at the CAOC 0 Conference in San Francisco.. I was selected for membership into 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, California. 0 CASE NO. :-cv-00 JVS (AFMx)

11 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 0. In January of 0, I spoke on the impact of the Federal Communications Comission s 0 Declaratory Ruling on TCPA litigation at the ABA National Convention in Salt Lake City, Utah.. In May of 0, I spoke on Class Action Trends at the CAOC seminar in Palm Springs, California. 0. I lectured on the TCPA before the ABA Business Law Section, Consumer Financial Services Committee in January 0 at an event in Utah entitled, Impact of the FCC s 0 Rulings on TCPA Litigation.. In 0, I wrote an article entitled Finding a Balance that was published in the Nutrition Business Journal, concerning a lawsuit filed under the Racketeer Influenced and Corrupt Organization Act.. I was published in the Daily Journal in September of 0, with the title, The FDCPA: The Forgotten Statute.. I am often called upon to give legal analysis on popular television and radio shows such as Dr. Drew Midday Live and Fox.. In March of 0, I moderated the Judges Panel on Class Action Trends and Federal Litigation Trends at the NCLC Conference.. I spoke on privacy rights on a panel before the California State Bar Convention in 0.. I am scheduled to speak at the nd National Forum on Residential Mortgage Litigation & Regulatory Enforcement conference on January, 0.. I am a member in good standing of the following local and national associations: a. Consumer Attorneys Association of Los Angeles; b. The Orange County Bar Association; c. Twice served as former President of the Orange County Chapter of the Iranian American Bar Association; d. Member of the Orange County Trial Lawyers Association; CASE NO. :-cv-00 JVS (AFMx)

12 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: 0 e. Member in good standing of National Association of Consumer Advocates; f. Member of Consumer Attorneys of California; g. Member of the Federal Bar Association; h. Member of the Leading Forum of the American Association of Justice; i. Member of the American Bar Association; j. Member of the Western Trial Lawyers Association. EXHIBITS. Attached as Exhibit A is a true and correct copy of the Attorney s Fees Report for Kazerouni Law Group and Hyde & Swigart, detailing Plaintiffs detailed billing records as well as costs incurred in litigating this matter. I declare under penalty of perjury, under the laws of the United States and the State of California, that the foregoing is true and correct. Executed this th day of June 0, at San Diego, California. By: /s/ Abbas Kazerounian Abbas Kazerounian 0 CASE NO. :-cv-00 JVS (AFMx)

13 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: Exhibit A Attorneys Fees and Costs Report

14 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: Time Sheets for Medeiros v. HSBC } Hyde & Swigart $,.0 David J. McGlothlin, ATTORNEY (AT $.00 per hr.) July, 0 Initial Interview With Client - Discuss Potential Case. Sent client fee agreement and intake Soft File Created Initial research prior to filing complaint, calls to each named plaintiff July, 0 Draft complaint and corresponding filing documents July, 0 Discuss case with co-counsel, revise complaint November 0, 0 Draft of First Amended Complaint, send to co-counsel to review November, 0 Finalize and have filed the FAC November, 0 Prepare waiver of service January, 0 Review Defendant's answer March, 0 Discussions with co-counsel and opposing counsel about upcoming ENE and possibly appearing telephonically. March, 0 Revisions to joint motion to appear telephonically at ENE March, 0 Draft ENE Brief Calls to clients April, 0 Draft of discovery plan, send to OC April, 0 exchange with class reps updating them on status of case April 0, 0 exchange with OC, revisions to joint report Confirm issues in joint report with all co-counsel, finalize report, and e-file April, 0 initial draft of discovery, send to JBS to review Meeting with JBS and JD to discuss case strategy April, 0 Finalize discovery and deposition notices, give to staff to serve and set-up court reporter April 0, 0 Review case deadlines, discuss with co-counsel. Develop case strategy, timing issues 0.0 hrs. 0.0 hrs..0 hrs..0 hrs..0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs..0 hrs..0 hrs. 0.0 hrs. 0.0 hrs..0 hrs..0 hrs..0 hrs..0 hrs. 0.0 hrs.

15 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #:0 Time Sheets for Medeiros v. HSBC } May, 0 Review and anazlyze data from Defendant, discuss with co-counsel.0 hrs. Calls to clients May, 0 Draft mediation brief May, 0 Meeting, planning session with co-counsel in advance of mediation May, 0 Travel to and from and attend all day mediation June 0, 0 Draft confirmatory deposition notices, with new topics June, 0 Finalize deposition notices and document requests June, 0 Review discovery, prepare for depositions June, 0 Review case, data review, deposition prep June, 0 Data review, discuss with co-counsel June, 0 Data review, depo prep Continue data review June, 0 Travel to depositions, prep June 0, 0 Drive to depo, take them, drive back July, 0 Calls to clients July, 0 Conference call with JBS regarding motions, case strategy s with co-counsel re: motions February 0, 0 Draft Mediation brief Calls to clients February, 0 Travel to mediation Prepare for mediation, review both briefs, 0 pages of material February, 0 Attend all day mediation and return home.0 hrs..00 hrs..00 hrs. 0.0 hrs. 0.0 hrs..00 hrs..00 hrs..00 hrs..00 hrs..00 hrs..00 hrs..00 hrs. 0.0 hrs. 0.0 hrs..00 hrs..00 hrs..00 hrs..00 hrs.

16 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: Time Sheets for Medeiros v. HSBC } February, 0 Discuss case strategy with JBS/AK, with Fanning a plaintiff's about discovery 0.0 hrs. and stip March, 0 Travel to and prep for mediation. Meetings with co-counsel. Review data Calls to clients March, 0 Attend and Travel from mediation March, 0 Review case, prepare task for Erin to prep mediation documents March, 0 Calls to clients regarding settlement June, 0 Review settlement term sheet, discuss with co-counsel Call to Fanning counsel on term sheet June, 0 DIscuss claims admin bids with co-counsel, review settlement and create first draft of letter to solicit claims admin bids. June, 0 Review claim admin letter, joint motion, s with co-counsel July, 0 Review stipulations regarding consolidating cases, and continuing deadlies August, 0 Review and compare claims admin bids, create chart, discuss with co-counsel August, 0 Spoke with AK re: claims admin, to co-counsel Eve..00 hrs..00 hrs. 0.0 hrs..0 hrs. 0.0 hrs..0 hrs..0 hrs. 0.0 hrs..0 hrs. 0.0 hrs. August, 0 /- Left VM for client 0.0 hrs. ed Medeiros client regarding settlement 0.0 hrs. s with class reps 0.0 hrs. Review release, discuss with co-counsel.0 hrs. August, 0 Final review of settlement agreements and motion documents Conversations and s with all class reps. Answer any further questions on settlement, obtain signatures. September 0, 0 s with class rep medeiros October 0, 0 Review court's preliminary approval order November, 0 Review copy of publication notice.00 hrs..0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs.

17 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: Time Sheets for Medeiros v. HSBC } December, 0 Review correspondence regarding notice being sent and data provided 0.0 hrs. January 0, 0 Discuss case with co-counsel January, 0 Conference call with OC and Cap One regarding missing data February, 0 Reviewed IVR script, discussed with co-counsel March, 0 Review notices, scripts, s regarding settlement March, 0 Review website, check claims process, review content March, 0 s with co-counsel regarding class lists. March, 0 Review case status, discuss with co-counsel March, 0 Review court order, check case status, respond to attorney that inquired about opt-out deadline April, 0 Review IVR, claims admin June 0, 0 Calls to class reps Draft declarations for all class reps, to them June, 0 review status report from claims admin. Discuss with co-counsel. Joshua B. Swigart, ATTORNEY (AT $0.00 per hr.) August, 0 Draft informal discovery March, 0 Prepare for ENE; telephonic Attend ENE; telephonic Briefing re post ENE April, 0 Prepare for CMC Attend telephone CMC Meeting with co-counsel April, 0 Draft discovery May, 0 Review and analyze data from D David J. McGlothlin, In Summary: $, hrs. 0.0 hrs..00 hrs..0 hrs..00 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs..0 hrs..0 hrs..0 hrs. 0.0 hrs..0 hrs..00 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs..0 hrs..00 hrs..0 hrs.

18 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: May, 0 Prepare for mediation, review docs, meet with co-counsel May, 0 Travel to and from, attend all day mediation with HSBC June, 0 Data review, depo prep June, 0 Continue reviewing data provided by HSBC, deposition prep June, 0 Data review for HSBC deposition June 0, 0 Take depositions of PMK December, 0 December, 0 Conf. call with counsel December, 0 to OC Arjun February, 0 JBS/DJM to appear at Mederios mediation on / February, 0 Review Fanning's mediation brief February, 0 Review HSBC mediation brief February, 0 Travel to mediation February, 0 Attend mediation and return Settlement Recap; see notes February, 0 Stip filed to continue scheduling conf. Time Sheets for Medeiros v. HSBC } February, 0 Order granting continuance of schedulng confernece to / at :0; JBS updated the calendar March, 0 Prep and travel to mediation March, 0 Attend mediation Travel from mediation March, 0 Review correspondence from mediator Judge Infante.0 hrs..0 hrs..00 hrs..00 hrs..00 hrs..00 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs..00 hrs..00 hrs..00 hrs..00 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs..00 hrs..00 hrs..00 hrs. 0.0 hrs.

19 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: correspondence regarding settlement April, 0 Order from court vacating the / hearing; JBS updating calendar April, 0 Order allowing briefing schedule May, 0 Fanning Terms Sheet June, 0 Conf. call with OC re consolidation Conf. with co counsel re consolidation to Cervantes re consolidation June, 0 Call to Eve Cervantez; discuss notice; to McGlothlin for letter Review Lindgren edits June, 0 Draft letter to claims administrator for bid Time Sheets for Medeiros v. HSBC } 0.0 hrs. June, 0 Review Joint Motion to consolidate Review Joint Motion; redline and send changes to TF and group Review filed joint stipulation to continue deadline to file preliminary approval Review joint stipulation to consolidate; conf. calls and s on effects of language June, 0 Review claims admin letter Redraft admin letter and send to Eve Review Joint motion and from Cervantez Review revised stip by DJM June, 0 Review additional draft of Cervantez Make final changes to the letter and copy Eve on draft to Shannon Order granting stipulation to file preliminary approval to 0 days after / June, 0 from Cervantez group re AB data serving as class administrators August, 0 Revised docs for preliminary approval from co-counsel August, 0 Review filed motion for preliminary approval November, 0 Copy of publication notice November, 0 Notice documents 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs..00 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs.

20 Case :-cv-00-jvs-rnb Document - Filed 0// Page 0 of Page ID #: November 0, 0 Notice documents January, 0 Joint stip to continue final approval hearing May, 0 Review finalized documents from claims admin June, 0 KCC status report June, 0 Status report; review Jessica Dorman, ATTORNEY (AT $.00 per hr.) April, 0 Meeting with partners discuss case strategy May, 0 Review categorize, summarize discovery and data Joshua B. Swigart, In Summary: Time Sheets for Medeiros v. HSBC } $,.00 May, 0 Review categorize, summarize discovery and data, present to partners in advance of mediation May, 0 Attend meetings, discuss data in advance of mediation June, 0 Data review, organize documents, discuss with DJM/JBS/AK June, 0 Data review, organize, discuss June, 0 Review Data discuss with co-counsel June, 0 continue data and document review Jessica Dorman, In Summary: $,.0 Krysti A. Ruddle, CLERK (AT $.00 per hr.) September, 0 Received Scheduled Hearing on 0// Time: 0:00 am Mediator: Honorable Leo Papas Place: 0 S. Figueroa St. Ste. 000, Los Angeles, CA 00 (. Hr) Krysti A. Ruddle, In Summary: Front Desk, FRONT DESK (AT $.00 per hr.) April, 0 mailed disc. reqs. & depo. w/ltr to OC (. Hr) mailed second set of disc. reqs. notice of depo, and ltr to OC (. Hr) $0.00 June, 0 mailed P's amended notice of depo. sets one on 0// & 0// to OC (. Hr) Front Desk, In Summary: $ hrs. 0.0 hrs..00 hrs. 0.0 hrs. 0.0 hrs..0 hrs..0 hrs..00 hrs..00 hrs..00 hrs..00 hrs..00 hrs..00 hrs..00 hrs..0 hrs.

21 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: Time Sheets for Medeiros v. HSBC } Erin O'Rourke, PARALEGAL (AT $0.00 per hr.) March, 0 Finished organizing a Mediation Binder (. Hr) August, 0 Called and spoke w/ client re signing SA and sending back by tomorrow (. Hr) Eva Dickey, PARALEGAL (AT $0.00 per hr.) July, 0 Finished Redlining Complaint (. Hr) Efiled Complaint and Civil Cover Sheet (. Hr) March, 0 Drafted Upcoming ENE Letter (. Hr) Erin O'Rourke, In Summary: $0.00 March, 0 Sending ENE Notice to clients (Medeiros, Morrissey, Pulatie, Bomberger) via GSO (. Hr) January, 0 Efiled Jt Mtn to Continue Scheduling Conference/Set Hearing Dates re: Prelim Approval; lodged Proposed Order (. Hr) Eva Dickey, In Summary: $0.00

22 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: Time Sheets for Medeiros v. HSBC } Kaz LG $,.00 Abbas Kazerounian, ATTORNEY (AT $0.00 per hr.) May, 0 Review analyze data, meetings with co-counsel, discuss case strategy, prepare for mediation May, 0 Prepare for mediation May, 0 Travel to and from, attend all day mediation June, 0 Analyze data, review discovery responses June, 0 Several meetings, review data, discuss with JBS/DJM/JD June, 0 Review data, discovery, meetings, depo prep June, 0 Meetings, depo prep, review discovery and data June 0, 0 prepare and take 0b depositions February, 0 Began reviewing the mediation brief for intervenors (0 pages) February, 0 Reviewed brief for HSBC Conf call with DJM re HSBC stance February, 0 Traveled to SF and prepped for mediation with cocounsel February, 0 Attended all day mediation and traveled home March, 0 Traveled to SF for mediation. Met with JBS and DJM re prep for mediation March, 0 Attended mediation and traveled home. March, 0 Spoke to Infante re: mediation Conversation with JBS July, 0 Call with Epiq re bid and requirements Call withkcc re bid and requirements exchange with ANgeon re bid July, 0 Traveled to LA to speak to Pat Ivie from KCC in person about their bid and traveled home.00 hrs..00 hrs. 0.0 hrs..0 hrs..00 hrs..00 hrs..0 hrs..00 hrs..0 hrs. 0.0 hrs. 0.0 hrs..0 hrs..0 hrs..0 hrs..0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs. 0.0 hrs..0 hrs.

23 Case :-cv-00-jvs-rnb Document - Filed 0// Page of Page ID #: July, 0 Conf call with Epiq re their bid August, 0 Spoke with KCC regarding claims admin bid August, 0 I ed Pat Ivie at KCC and asked for resume Reviewed release and asked David to do the same August, 0 Reviewed all exhibits to SA and sent to DM for review also Reviewed KCC dec and resume for prelim papers - sent to co counsel to get her redlines also August, 0 Reviewed edited docs and exhibits from D counsel October, 0 I prepped for prelim hearing and appeared - approved November, 0 Review notice documents sent by claims administrator March, 0 Review scripts, website, notice issues. Discuss with co-counsel June, 0 Reviewed claim rate Time Sheets for Medeiros v. HSBC } Abbas Kazerounian, In Summary: $,.00 Total Fees (For The Entire Firm): $, hrs. 0.0 hrs. 0.0 hrs..0 hrs..0 hrs. 0.0 hrs..0 hrs..0 hrs..00 hrs..0 hrs. 0.0 hrs..0 hrs.