UNITED STATES DISTRICT COURT CLASS ACTION. Frederick F. Mumm. JURRY TRIAL DEMAND Defendant Complaint Filed: March 24, 2015

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1 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page 1 of 1 Page ID #:83 Timothy Blood (133) BLOOD HURST & O'REARDON, LLP 00 B Street, Suite 50 San Diego, California 01 3 Tel: (1) tblood@bholaw.com Ben Bamow 5 b.bamow@bamowlaw.com Erich P. Schork e.schork@bamowlaw.com BARNOW AND ASSOCIATES, P.C. 1 North LaSalle Street, Suite 00 8 Chicago, Illinois 00 Tel: (31) -00 l 1o Philip J. Milligan (pro hac vice) MILLIGAN LAW OFFICES 500 South th Street Fort Smith, Arkansas 01 1 Tel: ()83- milliganlaw@sbcglobal.net Michael L. Roberts (pro hac vice) ROBERTS LAW FIRM, P.A. Rahling Circle P.O. Box 0 Little Rock, Arkansas Tel: 501/8-555 (501)8- (fax) mikero berts@robertslawfirm. us Jeffrey S. Hurst (8) MONTELEONE & McCORY, LLP South Figueroa Street, Suite 30 Los Angeles, CA 00 Tel: 3/ (3) 1-30 (fax) hurst@mmlawyers.com 1 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA BRIAN WARNER, KENNETH MACLEOD, MICHAEL MEADE, MICHAEL WATSON, JAMES 1 FULLER AND DALE FRANQUET individually and on behalf of all others similarly situated, V. TOYOTA MOTOR SALES U.S.A., INC, A California corporation, CLASS ACTION DECLARATION OF MIKE ROBERTS IN SUPPORT OF REQUEST FOR ATTORNEY FEES AND EXPENSES Plaintiffs, Case No. :-cv-0-fmo-(ffmx) USDJ: Ctrm: USMJ: Ctrm: Fernando M. Olguin, 5th Floor - Spring Frederick F. Mumm E, th Floor - Spring JURRY TRIAL DEMAND Defendant Complaint Filed: March, f ' 1 Case No. :-cv-0-fmo-(ffmx)

2 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page of 1 Page ID #:8 I, Mike Roberts, declare as follows: I am managing partner at the firm of Roberts Law Firm, PA. I submit this 3 declaration in support of Representative Plaintiffs' motion for an award of attorneys' fees, costs, and expenses in connection with services rendered in the 5 above-captioned litigation. I make this declaration based on personal knowledge. If called as a witness, I could and would testify competently as to the matters stated herein Roberts Law Firm was retained directly by Kenneth MacLeod a Class Representative in this action. Roberts Law Firm, PA has undertaken this litigation solely on a contingency fee basis. During the course of this litigation, Roberts Law Firm, PA has been involved in the following activities on behalf of the Settlement Class: Roberts Law 1 Firm was involved in most aspects of discovery, document production, drafting pleadings, plaintiffs' litigation strategy, updating named plaintiff client, among other tasks. The information in this declaration regarding my firm's time and expenses is l 8 taken from time and expense printouts and supporting documentation prepared and l maintained by the firm in the ordinary course of business. Attached hereto as Exhibit 1 is a summary of the firm's lodestar from the inception of this matter to February,. The summary includes the names of attorneys and professional support staff who worked on this case, the bar admission year for each attorney, and each timekeeper's respective hours and lodestar at current rates. The hourly rates shown in Exhibit 1 are the usual and customary rates set by the firm for each individual. My firm has expended 8.1 hours working on this case from its inception until February,. Total lodestar for my firm is $0,.00. Case No. :-cv-0-fmo-(ffmx)

3 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page 3 of 1 Page ID #:85 1 My finn has expended $,.08 in costs and expenses in this case from inception until February,, in connection with the prosecution of this case. 3 Those costs and expenses are summarized by category in Exhibit. The costs and expenses pertaining to this case are reflected in the books and 5 records of the firm. These books and records are prepared form receipts, expense vouchers, check records, and other documents and are an accurate record of the costs and expenses. 8 The background and experience of Roberts Law Firm, PA is summarized in the resume attached hereto as Exhibit I declare under penalty of perjury that the foregoing is true and correct to the 1 best of my knowledge. 1 Executed this th day of February,, at Little Rock, AR. Mike Roberts 1 3 Case No. :-cv-0-fmo-(ffmx)

4 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page of 1 Page ID #:8 Exhibit 1

5 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page 5 of 1 Page ID #:8 1 EXHIBIT 1 3 ROBERTS LAW FIRM, PA Time Report Inception through February, Name (Position) Mike Roberts, Partner Debra Josephson, Partner Emily Neal, Partner Jing Zhao, Assoc. Jana Law, Partner Karen Halbert, Partner Stephanie Smith, Partner April Burton, Paralegal Angelicia Isclaw, Paralegal GRAND TOTAL Year of Bar Admission Hours Rate Lodestar $,85.00 $,53.00 $30,.00 $8,3.00 $,55.00 $,.00 $1,1.00 $80 $1, $0, Case No. :-cv-0-fmo-(ffmx)

6 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page of 1 Page ID #:88 Exhibit

7 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page of 1 Page ID #: EXHIBIT ROBERTS LAW FIRM, PA Costs and Expenses Summary Inception through February, CATEGORY TOTAL Transportation, Hotels, and Meals $0.00 Telephone, Facsimile $0.00 Postage/Overnight Delivery $0.00 Messenger, Overnight Delivery $0.00 Photocopies $0.00 Electronic Research $1,5.08 Litigation Fund Contribution $0.00 Court Fees $0.00 Witness/Service Fees $0.00 Miscellaneous (Discovery Database Vendor Access Fees) $50.00 GRAND TOTAL $,.08 I 5 Case No. :-cv-0-fmo-(ffmx)

8 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page 8 of 1 Page ID #:0 Exhibit 3

9 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page of 1 Page ID #:1 1 EXHIBIT3 FIRM RESUME 3 OF ROBERTS LAW FIRM, PA 5 Roberts Law Firm, P.A. is a Certified Minority Business Enterprise, and is based in Little Rock, Arkansas. The law firm has three divisions: Corporate, Intellectual 8 Property, and Complex Class Litigation. The law firm's practice predominately involves complex class action litigation representing corporate clients to recover 1O from defendants stemming from wrongful or illegal conduct. The firm has served as counsel for Plaintiff-Corporations in individual and class action cases, and has 1 successfully assisted recovery of hundreds of millions of dollars for its corporate clients. 1 Mike L. Roberts has served as co-lead counsel in multiple complex class actions, including the following (In Re: Microsoft Antitrust Indirect Purchaser Litigation in Arkansas (case settled early); In Re: Pilot Flying J Rebate (a nationwide class action which settled within two () months from our initially filed complaint); In 1 Re: Aftermarket Automotive Sheet Metal Antitrust Third Party Purchaser Litigation. (See below.) Mr. Roberts served as Co-Lead Settlement Class Counsel in Ori vs. Fifth Third Bank case and also served on the Plaintiffs' Steering Committee in the Heartland Bank data breach case. (See below.) In addition, Mike L. Roberts is a seasoned economic developer, helping corporate clients around the globe with various business opportunities. On February 1, 08, Governor Mike Beebe appointed Mr. Roberts to the Arkansas Economic Development Commission ("AEDC") to serve as a Commissioner. Mr. Roberts works with companies who either already have a presence in Arkansas or who are Case No. :-cv-0-fmo-(ffmx)

10 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page 10 of 1 Page ID #: 1 considering Arkansas or somewhere else in the United States to establish its business or manufacturing production plant. In, Mr. Roberts was reappointed 3 by Governor Asa Hutchinson to a third term on the AEDC. 5 Mr. Roberts is licensed in Arkansas, Florida, Tennessee, Texas, and New York. He is also licensed before the United States Supreme Court and several U.S. Federal District Courts in the U.S. The firm handles litigation in multi-states in the United 8 States, and handles claims for corporate clients globally. Clients include 1o corporations from Abu Dhabi, Dubai, Greece, England, Taiwan, China, Vietnam, and the United States. 1 Roberts Law Firm, P.A. is a Certified Minority Business Enterprise. The firm's majority owner (Mike L. Roberts) is a certified minority. The firm is a member of 1 the NAMWOLF (The National Association of Minority and Women Owned Law Firms, Inc.) and is also a member of the National Minority Supplier Development Council, Inc. Partial Client List 1 Tyson Foods Corporation, AT&T Corporation, Georgia Pacific Corporation, Home Depot Stores, Federal Express Corporation, Southwest Airlines, USA Drug Stores, Inc., Walgreens, Inc., RBX Industries, ASUSTek Computer, Inc. (Taiwan), Compal Electronics, Inc. (Taiwan), AMTRAN Technology Co., Ltd (Taiwan), F oxlink International, Inc. Sample of Significant Cases of Roberts Law Firm In Re: Parking Heaters Antitrust Litig., United States District Court for the Southern District of New York, Civil Action No. -mc-0-jg-jo (Appointed Co-Lead Interim Counsel for Direct Purchaser Plaintiffs). Case No. :-cv-0-fmo-(ffmx)

11 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page of 1 Page ID #:3 1 In Re: Heartland Payment Systems Inc. Customer Data Security Breach Litigation, 3 United States District Court for the Southern District of Texas, Civil Action No. H- 0-MD- (Appointed as Member of Steering Committee; case settled). 5 In Re: Ori vs. Fifth Third Bank and Fiserv, Inc., United States District Court for the Eastern District of Wisconsin, Civil Action No. 08-CV-003 -LA. (Appointed 8 Co-Lead Settlement Class Counsel; case settled). 1O National Trucking Financial Reclamation Services, LLC vs. Pilot Corporation, ll Pilot Travel Centers d/b/a Pilot Flying J, et al, United States District Court for the 1 Eastern District of Arkansas, Case No.: :-cv-000-jmm. (Appointed Co-Lead Counsel; case settled in two months for $8 million plus injunctive relief and final 1 approval was entered within months of initially filed complaint). l AM Sheet Metal Litigation, United States District Court for the Eastern District of Wisconsin, No. : CV 00 - LA (Appointed Co-Lead Counsel for Indirect Purchaser Plaintiffs). (Case settled with three of four defendants) 1 In Re: Microsoft Antitrust Litigation: Paul Peek, D.D.S., et al. v. Microsoft Corporation, Circuit Comi of Lonoke County, Arkansas, First Division, No. CV0-80 (Co-Lead Counsel) (Order approved Final Settlement on March, 0, State of Arkansas; case settled for $3 million). In Re: U S. DRAM Antitrust Litigation: Bruce K. Burton, MD., P.A. Malvern Diagnostic Clinic, et al. v. Micron Technology, Inc., et al., Circuit Court of Hot Springs County, Arkansas, First Division, Case No. CV-0--1 (Class Counsel -Case has settled for $300 million) 8 Case No. :-cv-0-fmo-(ffmx)

12 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page 1 of 1 Page ID #: In Re: Augmentin Litigation, United States District Court for the Eastern District of 3 Virginia, No. :0cv; Ryan-House et al. v. GlaxoSmithKline et al., United States District Court for the Eastern District of Virginia, No. :0cv (Plaintiffs 5 Class Counsel -case settled for $1 million.) In Re: Nifedipine Litigation, United States District Court for the District of 8 Columbia, No. 0-CIV- 00 (RJL). SAJ Distributors, Inc. v. Biovail 10 Corporation, United States District Court for the District of Columbia, No 0-CIV00 (RJL) (Plaintiffs class counsel; case settled for $0 million). 1 Hypodermic Products Antitrust Litigation, United States District Court for the District of New Jersey, Docket No (JLL/RJH), MDL No (Plaintiffs class counsel). In R:e Imodium Advanced Antitrust Litigation, United States District Court Eastern District of Pennsylvania, Master File No. 0cv03; SAJ Distributors, Inc. vs. McNeil-PPC, Inc., United States District Court for the Eastern District of 1 Pennsylvania, Civil Action No. 0-3 (Plaintiffs class counsel). In Re: Oxycontin Antitrust Litigation, United States District Court for the Southern District of New York, MDL Docket No. 03; SAJ Distributors, Inc. et al. v. The Purdue Pharma Co. et al., United States District Court for the Southern District of New York, MDL Docket No. 03 (Case settled: $ million). In Re: Payment Card Interchange Fee and Merchant Discount Antitrust Litigation, United States District Court Eastern District of New York, Master File No. 05- MD- 1 (JG)(JO) (Plaintiffs class counsel). Case No. :-cv-0-fmo-(ffmx)

13 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page of 1 Page ID #:5 1 In Re: Wellbutrin SR Antitrust Litigation, United States District Court for the 3 Eastern District of Pennsylvania, Master File No. 0-CV-55 (Case settled - $ million). 5 In Re: Skelaxin Antitrust Litigation, United States District Court for the Eastern District of Tennessee, I :J -md-03-clc (Case settled - $3 million). 8 In Re: Rubber Chemicals Antitrust Litigation, (filed on behalf ofrbx Chemicals 1 O as individual action and settled: confidential terms) Case No. :-cv-0-fmo-(ffmx)

14 Case :-cv-0-fmo-ffm Document 1- Filed 0// Page 1 of 1 Page ID #: BLOOD HURST & O REARDON, LLP CERTIFICATE OF SERVICE I hereby certify that on February,, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the addresses denoted on the Electronic Mail Notice List, and I hereby certify that I have mailed the foregoing document or paper via the United States Postal Service to the non-cm/ecf participants indicated on the Electronic Mail Notice List. I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on February,. s/ Timothy G. Blood TIMOTHY G. BLOOD BLOOD HURST & O REARDON, LLP 01 B Street, Suite 00 San Diego, CA 01 Telephone: 1/ / (fax) tblood@bholaw.com Case No. :-cv-0 FMO (FFMx)