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1 MARLIN & SALTZMAN, LLP Stanley D. Saltzman, Esq. (SBN Agoura Road, Suite Agoura Hills, California 1 Telephone: ( Facsimile: ( ssaltzman@marlinsaltzman.com Attorneys for Plaintiff and the Proposed Class SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL CIVIL WEST SUNSHINE LLAMB, an individual, on behalf of herself and all others similarly situated, vs. Plaintiff, SFD FILMS, INC. dba SASSOON FILM DESIGNS; TIM SASSOON, an individual; and DOES 1 through 0, inclusive, Defendants. CASE NO: BC (Assigned to Hon. Elihu M. Berle, CCW CLASS ACTION NOTICE OF MOTION AND MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT; MEMORANDUM OF POINTS AND AUTHORITIES DATE: February, 01 TIME: :0 a.m. DEPT: CCW 0 1

2 1 TABLE OF CONTENTS I. ARGUMENT...1 A. The Proposed Settlement Warrants Final Approval Because It Is A Fair, Adequate, and Reasonable Compromise In Light Of Defendants Potential Liability, The Risks Of Continued Litigation and the Substantial Reduction of Defendants Operations...1 B. The Proposed Settlement is Entitled to a Presumption of Fairness Because It Was Reached Through Arm s-length, Non-Collusive, and Informed Negotiations The Settlement Is the Product Arm s-length Negotiations by Informed Counsel.... Sufficient Discovery Has Been Completed to Warrant Settlement.... Highly Experienced Counsel Endorses the Settlement.... No Objections Have Been Made to the Settlement... II. THE CLASS SHOULD BE CERTIFIED FOR SETTLEMENT PURPOSES... III. CONCLUSION i

3 TABLE OF AUTHORITIES STATE CASES -Eleven Owners for Fair Franchising v. Southland Corp. (000 Cal.App.th... 1, Daar v. Yellow Cab. Co. ( Cal.d... Dunk v. Ford Motor Company ( Cal.App.th... 1,,, Kullar v. Foot Locker Retail, Inc. (00 1 Cal.App.th... 1,,, Malibu Outrigger Bd. of Governors v. Superior Court (0 Cal.App.d... Richmond v. Dart Indus., Inc. (1 Cal.d... Wershba v. Apple Computers, Inc. (001 1 Cal.App.th... 1, FEDERAL CASES Officers for Justice v. Civil Service Com. (th Cir. F.d Rodriguez v. West Publishing Corp. (th Cir. 00 F.d... STATUTES AND RULES Cal. Civ. Proc.... 1, OTHER AUTHORITIES Newberg on Class Actions... ii

4 TO: NOTICE OF MOTION ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 1 PLEASE TAKE NOTICE that on February, 01, at :00 a.m., or as soon thereafter as the matter may be heard in Department CCW, before the Honorable Elihu M. Berle, located at 00 S. Commonwealth Street, Street, Los Angeles, California, 000, Plaintiff Sunshine Llamb ( Plaintiff and SFD FILMS, INC. dba SASSOON FILM DESIGNS; TIM SASSOON (hereinafter Defendants will move the Court to grant final approval of the proposed class action settlement. Plaintiff brings this Motion on the grounds that the proposed settlement is within the range of reasonableness to be finally approved as fair, adequate, and reasonable in all respects. This Motion is based upon the attached Memorandum of Points and Authorities, the parties Joint Stipulation of Class Action Settlement and Release, the Declaration of Stanley D. Saltzman, and any such further evidence and argument as the Court may consider at the hearing on Plaintiff s Motion DATED: January 1, 01 MARLIN & SALTZMAN, LLP By: Stanley D. Saltzman, Esq. Attorneys for Plaintiff and Proposed Class iii

5 MEMORANDUM OF POINTS AND AUTHORITIES I. ARGUMENT A. The Proposed Settlement Warrants Final Approval Because It Is A Fair, Adequate, and Reasonable Compromise In Light Of Defendants Potential Liability, The Risks Of Continued Litigation and the Substantial Reduction of Defendants Operations Particularly in complex class action litigation, [v]oluntary conciliation and settlement are the preferred means of dispute resolution. (-Eleven Owners for Fair Franchising v. Southland Corp. (000 Cal.App.th, 1 (quoting Officers for Justice v. Civil Service Com. (th Cir. F.d 1,. The trial court has broad discretion in reviewing a proposed class settlement for approval. (Wershba v. Apple Computers, Inc. (001 1 Cal.App.th, - ( Wershba ; Kullar v. Foot Locker Retail, Inc. (00 1 Cal.App.th, 1- ( Kullar. In deciding whether to grant final approval to a proposed class action settlement under Code of Civil Procedure section, the Court s overriding concern is whether the proposed settlement is fair, adequate, and reasonable. (Dunk v. Ford Motor Company ( Cal.App.th, 1 ( Dunk. Courts consider a number of factors in evaluating the fairness of a proposed settlement, including: (1 the strength of the plaintiff s case; ( the risk, expense, complexity, and likely duration of further litigation; ( the risk of maintaining class action status through trial; ( the benefits conferred by settlement; ( the experience and views of class counsel; ( the extent of discovery completed and the state of the proceedings; and ( the reaction of class members to the proposed settlement. (Dunk, supra, Cal.App.th at. This list is not exhaustive and should be tailored to each case. Due regard should be given to what is otherwise a private consensual agreement between the parties. (Id. at 1. The trial court bears the responsibility of ensuring that the settlement is a reasonable compromise, given the magnitude and apparent merit of the claims being released, discounted by the risks and expenses of attempting to establish and collect on those claims by pursuing the litigation. (Kullar, supra, 1 Cal.App.th at. Ultimately, the court s determination is nothing more than an amalgam of delicate balancing, gross approximations and rough justice. (Dunk, supra, Cal.App.th at 1 (internal citations and quotations omitted. As previously detailed in Plaintiffs Motion for Preliminary Approval and Motion for Attorneys 1

6 Fees, Costs, and Service Awards, and more specifically in the detailed supplemental declaration of Plaintiff s Counsel submitted on March, 01 at the Court s request, the proposed settlement satisfies all of the above factors. The Supplemental Declaration addressed in detail the so-called Kullar factors. Rather than repeat that full discussion herein, the Court is respectfully referred to said declaration, the content of which is respectfully incorporated herein by reference thereto. The proposed settlement before the Court is a fair, reasonable, and adequate compromise in light of Defendants potential liability on the primary claim of failure to pay the overtime premium rate on the overtime hours worked, and also based on the defenses asserted as to the remaining secondary claims, as well as the continued risks of ongoing litigation and the likely difficulty of obtaining certification on the secondary claims. Absent settlement, Plaintiff would have been required to adjudicate all class liability and certification issues in the trial court and on potential appeals, all of which could have entailed significant investments of time and resources from the Parties, and could well have led to the closure and/or bankruptcy of the Defendants, and extensive use of this Court s time over the course of several years in a battle over diminishing returns. In the face of these risks and realities, the Parties have reached this final settlement, which certainly provides real relief to those class members who worked the longer tenures, and some relief as well to the short term employees. Significantly, and as noted above, not a single class member has opted-out of or objected to the settlement. (Id. -1. B. The Proposed Settlement is Entitled to a Presumption of Fairness Because It Was Reached Through Arm s-length, Non-Collusive, and Informed Negotiations In order to prevent fraud, collusion or unfairness to the class, the settlement or dismissal of a class action requires court approval. (Malibu Outrigger Bd. of Governors v. Superior Court (0 Cal.App.d, -. Under California law, a presumption of fairness exists where: (1 the settlement is reached through arm s-length bargaining; ( investigation and discovery are sufficient to allow counsel and the court to act intelligently; ( counsel is experienced in litigating similar matters; and ( the percentage of objectors is relatively small. (See Dunk, supra, Cal.App.th at. Here, an agreement to settle was reached only after extensive investigation, litigation and

7 numerous, protracted arm s-length negotiations between counsel who are experienced in class action litigation and specifically in wage and hour class actions. (Saltzman Prelim. Approval Decl. -,. Experienced counsel on both sides were able to independently and thoroughly evaluate the claims and defenses asserted. The fairness, reasonableness, and adequacy of the settlement is further demonstrated by the fact that, after notice of the proposed settlement was disseminated to the class, not a single class member has as yet requested exclusion or objected to it. 1. The Settlement Is the Product Arm s-length Negotiations by Informed Counsel While the proponent of the settlement bears the burden of showing that it is fair and reasonable, courts generally recognize a presumption of fairness where the settlement agreement is the result of arm s-length bargaining. (Wershba, supra, 1 Cal.App.th at. Here, the proposed settlement is the product of thorough, protracted, arm s-length negotiations by experienced and informed counsel, with negotiations occurring on and off over the course of many months, even while Plaintiff s counsel was actively drafting the motion for class certification. As described in Plaintiff s preliminary approval papers, the Parties reached the agreement to settle only after completing substantial pre- and post-filing investigation and discovery, review and analysis of critical documents produced in conjunction with the negotiations, and numerous and regularly ongoing settlement discussions over the course of many months. The deposition of the Defendants PMK and owner, through witness Tim Sassoon, was critical in driving the matter into the highest level of settlement negotiations. Based on the extensive information and data obtained in advance of and throughout the parties settlement discussions, Class Counsel was able to thoroughly assess the strengths and weaknesses of the case and the benefits of settlement. This was fully set forth in the Supplemental Declaration of Saltzman referred to above. As a result of all the work and investigation, and given the totality of the circumstances presented, Class Counsel firmly believes that the proposed settlement represents a very favorable resolution of Plaintiff s and the class members claims. (Saltzman Decl., at 1. Sufficient Discovery Has Been Completed to Warrant Settlement The stage of the proceedings and the amount of discovery that has been completed are additional

8 factors courts consider in determining the fairness, reasonableness, and adequacy of a class action settlement. (See, e.g., Dunk, supra, Cal.App.th at 1-0. The focus is on whether sufficient discovery has been completed to allow counsel and the court to intelligently assess the issues and the possible resolution. (Id. at. Here, the Parties engaged in sufficient discovery to then allow class counsel to effectively depose Mr. Sassoon, both individually and as the corporate representative of the defendant entity. Extensive business and payroll records were compiled by the Defendants and produced to the Plaintiff, as to overtime pay issues, pay records and class membership. All of these records were thoroughly reviewed by Plaintiff s counsel prior to the deposition of the Defendant. With the assistance of the Class Representative, Plaintiff s counsel was also able to contact a significant number of the putative class members in order to obtain information necessary to further support the claims, and prepare for both depositions and possible certification. The information obtained, in addition to the timekeeping and payroll data, enabled Plaintiff s counsel to fully evaluate the claims and possible damages. By the time the Parties entered into settlement discussions, Plaintiff s counsel thus had considerable information available to it enabling it to complete a thorough evaluation of the strengths and weaknesses of the case. (Id. Based on the investigation and discovery conducted over the course of the litigation and given the magnitude and apparent merit of the claims being released, discounted by the risks and expenses of attempting to establish and collect on those claims by pursuing the litigation, a fair settlement has been reached. (See Kullar, supra, 1 Cal.App.th at.. Highly Experienced Counsel Endorses the Settlement Although recommendations of counsel proposing the settlement are not conclusive, courts can and do properly take them into account, particularly if they have considerable experience, are competent, have experience prosecuting similar litigation, and discovery has been conducted. See Newberg on Class Actions. (d ed.. Here, all those factors are present. Experienced counsel, who at all times participated in arm s-length settlement negotiations, has weighed all of the foregoing factors and endorses the proposed settlement. (Saltzman Prelim. Approval Decl. -1 As set forth in Class Counsel s declaration submitted in support of preliminary approval, Class Counsel has extensive experience litigating wage and hour class actions and other complex matters.

9 Over the course of the last twenty years, in literally over one hundred such class actions, the Marlin & Saltzman firm has been successful in obtaining over $0,000, in total settlements, and judgments, in class action matters. It has had the honor to have acted as counsel, lead counsel, and colead counsel in over the one hundred class actions alluded to above, many of which were brought on behalf of employees. (Saltzman Prelim. Approval Decl. 1- Class Counsel is thus uniquely qualified to evaluate the claims involved in this matter and the viability of the defenses asserted in this case, as well as to assess the potential benefits of settling compared to the exposures of proceeding with litigation. (Id. at. As noted, the Kullar presentation in this file record was extensively set forth in the Supplemental Declaration of Saltzman filed with this Court on March, 01. Given the risks inherent in litigation, particularly the risks related to obtaining and maintaining class certification, and then obtaining settlement payments from a greatly diminished set of defendants which could potentially face bankruptcy, Class Counsel strongly believes that the Settlement is fair, adequate and reasonable, and in the best interests of the Settlement Class. (Saltzman Prelim. Approval Decl. 1. No Objections Have Been Made to the Settlement On November, 01, the Court-approved notice was mailed to each of the 1 class members at their last known home address. (CPT Decl. The notice informed all class members of the critical terms of the settlement, and clearly set forth the amounts which could be sought for attorneys fees, costs, and the class representative service award. The notice also detailed the class members options with respect to the proposed settlement, including the right to dispute the data used to calculate their payment, request exclusion or object to the settlement. (Ibid. The 0-day response period will end on January, 01, and as of the date of this filing on January 1, 01, there have been no requests for exclusion or nor any objections to the settlement. (Id. CPT decl. at -1 Thus, assuming that nothing changes in the last two weeks following this filing, 0% of the 1 Settlement Class Members will end up participating in the Settlement. The Class Members complete and total endorsement of the settlement, as evidenced by the lack of objections, exclusions or disputes, is a major testament to the fairness, reasonableness, and adequacy of the proposed settlement. (See, e.g., Rodriguez v. West Publishing Corp. (th Cir. 00 F.d, (affirming approval of settlement where,000 out of,01 putative class members submitted claim

10 forms and objected to the settlement; -Eleven Owners for Fair Franchising, supra, Cal.App.th at - (finding that nine objections and 0 opt-outs in a class of, showed a positive response from class members supporting final approval. Accordingly, the Court should grant final approval of the settlement. II. THE CLASS SHOULD BE CERTIFIED FOR SETTLEMENT PURPOSES At the preliminary approval stage, Plaintiff presented briefing to support conditional class certification for settlement purposes. That argument is found at pages 1-1 of the preliminary approval motion. The Court granted that conditional class certification. There have been no intervening circumstances since preliminary approval which would warrant a change to the conditional class certification previously ordered by the Court. In order to avoid needless repetition of the arguments previously offered, the Court is respectfully referred thereto for purposes of this request that the case now be certified for settlement purposes and that Class Counsel and the representative Plaintiff be found to be adequate representatives, based on the prior discussion and the following brief arguments. Courts have generally found that class action suits are appropriate when the question is one of a common or general interest... or when the parties are numerous, and it is impracticable to bring them all before the court. (Cal. Civ. Proc. ; see also Richmond v. Dart Indus., Inc. (1 Cal.d, -. In order to sustain a class action, two requirements must be met: (1 there must be an ascertainable class; and ( there must be a well-defined community of interest in the questions of law and fact involved affecting the parties to be represented. (Daar v. Yellow Cab. Co. ( Cal.d, 0. As a general rule, a community of interest is established where (1 there are predominant common questions of law or fact; ( the named plaintiff has claims or defenses typical of the class ; and ( the named plaintiff is able to adequately represent the class. (See Dunk, supra, Cal.App.th at. California law and policy favors the fullest and most flexible use of the class action device. (Richmond, supra, Cal.d at -. This is especially so in the context of settlements, which enable those who have been harmed to achieve a measure of fair recovery. Since all of the above noted elements were presented and approved of at the preliminary approval stage, and there have been no changes, this class can and should now be certified for settlement purposes.

11 III. CONCLUSION Under California law, all of the requirements for final approval have been met. Therefore, Plaintiff respectfully requests that the Court now grant final approval of the proposed class action settlement, on the grounds that the settlement is fair, reasonable, and adequate, and provides substantial benefits to class members DATED: January 1, 01 MARLIN & SALTZMAN, LLP By: Stanley D. Saltzman, Esq. Attorneys for Plaintiff and Proposed Class

12 1 1 PROOF OF SERVICE Llamb v. SFD Films, Inc. dba Sassoon Film Designs, et al. STATE OF CALIFORNIA, COUNTY OF LOS ANGELES; I am employed in the County of Los Angeles, State of California. I am over the age of 1 and not a party to the within action; my business address is 00 Agoura Road, Suite, Agoura Hills, California, 1. On January 1, 01, I served the foregoing document(s: NOTICE OF MOTION AND MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT; MEMORANDUM OF POINTS AND AUTHORITIES. Pursuant to the Court s June, 01 Order Authorizing Electronic Service, the above-named documents have been electronically served on counsel of record by transmission through the Case Anywhere system on the date below. The transmission of these documents to the Case Anywhere system was reported as complete and a copy of the Case Anywhere Transaction Receipt will be maintained along with the original document(s and proof of service in our office. I declare under penalty of perjury, under the laws of the State of California that the foregoing is true and correct. Executed on January 1, 01, at Agoura Hills, California Sandy Laranjo PRYOR CASHMAN, LLP Thomas H. Vidal, Esq. (SBN 0 1 Century Park East, th Floor Los Angeles, California 00 Telephone: ( -0 Facsimile ( -0 Attorneys for Defendants SFD Films dba Sassoon Film Designs and Tim Sassoon

SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL CIVIL WEST ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

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