UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA DENISE REDDALL, individually, and on behalf of all others similarly situated,

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1 Case :-cv-00-ghk-agr Document - Filed 0/0/ Page of Page ID #: 0 0 Ira Spiro (State Bar No. ) ira@spirolawcorp.com Linh Hua (State Bar No. ) linh@spirolawcorp.com SPIRO LAW CORP. W. Olympic Blvd., th Floor Los Angeles, California 00- Tel: (0) -0 / Fax: (0) - Brian J. Mankin (State Bar No. ) bjm@fernandezlauby.com FERNANDEZ & LAUBY LLP 0 Allstate Drive Riverside, California 0 Tel.: ()0- / Fax: () 0- Attorneys for Plaintiff UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA DENISE REDDALL, individually, and on behalf of all others similarly situated, v. Plaintiff, QUEST DIAGNOSTICS, INC.; QUEST DIAGNOSTICS CLINICAL LABORATORIES, INC.; QUEST DIAGNOSTICS NICHOLS INSTITUTE; and DOES through 0, inclusive, Defendants. Case No.: CV -00-GHK(AGRx) [Assigned to the Hon. George H. King] DECLARATION OF DENISE REDDALL IN SUPPORT OF MOTION FOR AWARD OF ATTORNEYS FEES, COSTS, AND CLASS REPRESENTATIVE ENHANCEMENT PAYMENT

2 Case :-cv-00-ghk-agr Document - Filed 0/0/ Page of Page ID #: 0 0 DECLARATION OF DENISE REDDALL I, Denise Reddall, declare as follows:. I am the named plaintiff in the case of Reddall v. Quest Diagnostics, Inc., et al., Case No. CV -00-GHK(AGRx), pending in the United States District Court for the Central District of California.. This declaration is submitted in support of Plaintiff s Motion for Award of Attorneys Fees, Costs, and Class Representative Enhancement Payment. If called upon as a witness, I could and would competently testify to the following from my own personal knowledge.. On February, 0, I filed a putative class action Complaint against Quest for failure to pay overtime wages, failure to timely pay all wages earned each pay period, failure to pay final wages, and failure to provide accurate wage statements, along with derivative claims. The Complaint was later amended to include a claim for rest breaks and other penalties.. As the plaintiff in this lawsuit, I am aware of my responsibilities and duties to the class as a Class Representative. When I decided to start a proposed class action lawsuit, I understood that I was not only seeking compensation for myself, but also for all other current and former employees who were employed by Quest Diagnostics Incorporated, Quest Diagnostics Clinical Laboratories, Inc., and Quest Diagnostics Nichols Institute in nonexempt job positions throughout California. I understood that I could not put my interests above those of the Class Members. I am not aware of any interests of mine that would be antagonistic to, conflict with, or otherwise be adverse to the interests of the Settlement Class Members.. I learned that I had a duty to stay informed of what was happening in the case and could be asked to undertake a large amount of work as a Class

3 Case :-cv-00-ghk-agr Document - Filed 0/0/ Page of Page ID #: 0 0 Representative, and I agreed to accept those obligations. Since the filing of this lawsuit, I have maintained regular communications with my counsel and remained fully informed of the status of the case.. I have actively participated in the litigation and settlement of this case over the last two years. In April 0, I dropped off my young child at childcare and drove from Victorville, California to Riverside, California to meet with my counsel at the Fernandez & Lauby LLP offices. The meeting lasted approximately two hours. The commute time to child daycare, commute to Riverside, California, and the meeting with Mr. Mankin totaled approximately five hours. I paid for the cost of travel and childcare services. Throughout the litigation of my case, I spoke with Mr. Mankin about approximately five times, and each telephone call averaged approximately 0 minutes.. During the litigation of this action prior to the mediation, I spoke in great lengths with Ms. Hua, my counsel from Spiro Law Corp., and each call averaged approximately 0 minutes. I spoke with her approximately eight times to discuss various issues, including, but not limited to, factual allegations, workplace conditions, document analysis, and pay records. I spent approximately three hours searching for and reviewing documents to assist with litigating the case. I also spent approximately six hours communicating with another putative class member regarding the workplace conditions and the status of the case.. In October 0, I drove to the mediation in Los Angeles, California. The roundtrip commute to child daycare and from Victorville, California to Century City, Los Angeles for the mediation was approximately four and one-half hours. The mediation lasted approximately hours, past midnight. This was a very difficult, emotional process for me because my

4 Case :-cv-00-ghk-agr Document - Filed 0/0/ Page of Page ID #:0 0 0 young child was left overnight without my care, because the long and late hour was physically exhausting, and because the unfamiliar environment of lawyers discussing my work history with Quest caused great angst. I also paid for the cost of travel and overnight childcare services.. After the mediation, Ms. Hua and I continued to keep in regular contact regarding the status of my case. A significant amount of time was spent discussing the additional settlement negotiations, the proposed settlement terms, and updates regarding the court approval process. I estimate I spoke approximately 0 times with Ms. Hua for approximately minutes on each call. In connection with the proposed settlement and court approval process, I spent approximately three hours reviewing documents with Ms. Hua and independently. 0. Additionally, I have approximately two years of telephone records I can provide, for in camera review, to support my request for the Enhancement Payment. In total, I estimate I expended over 0 hours in assisting with the litigation of this case.. I understand that because I came forward to seek legal assistance with, what I believe to be, workplace violations against myself and other employees and remained committed to this case over the last two years, approximately, individuals may receive a cash benefit from the $00,000 Gross Settlement Fund, paid by Quest. After reviewing the terms of the proposed Settlement Agreement and discussing them with my counsel, I believe that the proposed Settlement fairly and adequately serves the best interests of the Settlement Class Members.

5 Case :-cv-00-ghk-agr Document - Filed 0/0/ Page of Page ID #: -J I declare under penalty of perjury under the laws of the State of California and the United States of Americathat the foregoing is true and correct. 0 t L t T t 0 Executed on August t, 0, at, California. DECLARATION OF DENISE REDDALL IN ST]PPORT OF MOTION FOR ATTORNEYS' FEES, COSTS, AND CLASS REPRESENTATTVE SERVICE AWARI)