Case 2:09-cv PSG-E Document Filed 11/03/17 Page 1 of 6 Page ID #:7167

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1 Case :0-cv-0-PSG-E Document - Filed /0/ Page of Page ID #: 0 0 MARLIN & SALTZMAN Stanley D. Saltzman, Esq. (SBN 00) Cody R. Kennedy, Esq. (SBN 0) 00 Agoura Road, Suite 0 Agoura Hills, California 0- Telephone: () -00 Facsimile: () -0 ssaltzman@marlinsaltzman.com ckennedy@marlinsaltzman.com LAW OFFICES OF PETER M. HART Peter M. Hart, Esq. (SBN ) Peter Choi, Esq. (SBN ) Wilshire Blvd., Suite 0 Los Angeles, California 00 Telephone: (0) - Facsimile: (0) - phart@msn.com pchoi.loph@gmail.com Attorneys for Plaintiffs Abdullah, et al., and the Class (additional counsel listed on next page) UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA MUHAMMED ABDULLAH, et al., as an individual and on behalf of all others similarly situated, v. Plaintiffs, U.S. SECURITY ASSOCIATES, INC., a Corporation, and DOES to 0, inclusive, Defendant. Case No. CV 0-0 PSG(Ex); Case No. CV -0 PSG(Ex) consolidated with Case No. CV-00 PSG(Ex) (Assigned to Hon. Philip S. Gutierrez) DECLARATION OF CODY R. KENNEDY ISO MOTION FOR FINAL APPROVAL OF CLASS ACTION SETTLEMENT DATE: December, 0 TIME: CTRM: :0 p.m. A Case No. CV 0-0 PSG(Ex)

2 Case :0-cv-0-PSG-E Document - Filed /0/ Page of Page ID #: 0 0 Additional Plaintiffs Counsel Kenneth H. Yoon, Esq. (SBN ) LAW OFFICES OF KENNETH H. YOON One Wilshire Blvd., Suite 00 Los Angeles, California 00 Telephone: () -0 Facsimile: () - kyoon@yoon-law.com Larry W. Lee, Esq. (SBN ) DIVERSITY LAW GROUP S. Figueroa St., Suite 0 Los Angeles, California 00 Telephone: () - Facsimile: () - lwlee@diversitylaw.com Peter R. Dione Kindem, Esq. (SBN ) THE DION-KINDEM LAW FIRM 0 Oxnard St., Suite 00 Woodland Hills, California Telephone: () -00 Facsimile: () -0 Peter@Dion-KindemLaw.com Case No. CV 0-0 PSG(Ex)

3 Case :0-cv-0-PSG-E Document - Filed /0/ Page of Page ID #: 0 0 I, Cody R. Kennedy, declare as follows:. I am an attorney licensed to practice in all Courts in the State of California. I am an associate with the firm of Marlin & Saltzman LLP, Co-Lead Counsel for the certified Class in the above-captioned action. I make this Declaration in support of Plaintiffs Motion for Approval of Attorneys Fees, Costs, and Incentive Awards and Motion for Final Approval in the above matter. Unless otherwise indicated, I have personal knowledge of the facts set forth herein and could competently testify to them if called as a witness.. In assisting with the drafting of the instant Motion for Final Approval and Motion For Approval of Attorneys Fees, Costs, and Incentive Awards, one of the tasks that I undertook involved reviewing the reports issued by third-party claims administrator CPT. This included conducting an in-depth review of all objections and opt-outs timely received by CPT, so that an accurate summary of the class reaction to the notices of settlement could be assembled.. The information provided by CPT indicates that after due notice to the, current and former employees identified by the Defendant s records as Class Members (with approximately.% of the notices undelivered), only six persons were listed as objecting to the settlement. This further breaks down into four persons who objected to the Settlement and two persons who were included in the objection statistic despite merely stating an intent to appear at the final approval hearing with no indication of any objection whatsoever. The objections, regardless of what they actually state, are attached to the CPT Dancy declaration, at Exhibit C thereto, pages C- through C-.. Upon review, none of the supposed objections can be considered substantive in any manner. Specifically, the responses received by CPT are more in line with class members simply writing letters sharing their own grievances relating to the Defendant.. Class-member Usha Bhasin (at C-, C- ) sent a notice of objection Case No. CV 0-0 PSG(Ex)

4 Case :0-cv-0-PSG-E Document - Filed /0/ Page of Page ID #:0 0 0 dated Oct. th, 0. Ms. Bhasin listed her legal basis supporting objection as follows: While working in US Security Associates, instead of $ per hour, they gave me $.00 per hour and last cheque, they gave me at the rate of $.00 per hour. Every time I got less money than my actual cheques.. Ms. Bhasin s objection does not cite any inadequacy with the noticed settlement amount nor the terms of the settlement. Additionally, Ms. Bhasin s the settlement. Therefore, Ms. Basin s objection does not appear to be a true objection to the settlement. To the extent that her issues may extend beyond the class claims, her Release as a class member would not include this matter.. Class-member Yogesh Kumar (at C-, C-) sent a notice of objection dated Oct. th, 0. Mr. Kumar listed his legal basis supporting objection as follows: Instead of $.00 per hour, they gave me $.00 per hour my last two cheques. They didn t give me and whenever I told to them to give my cheques, they flatly refused that they had given my payments. I called to them so many times, but in vain. I had pain in my spine so I could not take action & now please see my case and take action so I could receive all payments. They never paid me.. Mr. Kumar s objection likewise does not cite any inadequacy with the noticed settlement amount nor the terms of the settlement. Additionally, Mr. Kumar s the settlement. Therefore, Mr. Kumar s objection does not appear to be a true objection to the settlement. As was the case with Ms. Bhasin, to the extent that this issue may extend beyond the class claims, his Release as a class member would not include this matter. Case No. CV 0-0 PSG(Ex)

5 Case :0-cv-0-PSG-E Document - Filed /0/ Page of Page ID #: 0 0. Class-member LaChelle Burley (at C-) sent a notice of objection dated Oct. th, 0. Ms. Burley listed her basis of objection as follows: In my time of employment with US Security there were times where I didn t get paid on time or until the next pay period. I had to send a notarized letter to the Human Resources Department in Roswell, GA because they were in violation of waiting time penalties. They failed to keep accurate records of wages. I didn t get paid unused vacation time or for mandatory training. They failed to pay overtime wages and definitely didn t provide rest periods. 0. Ms. Burley s objection follows a similar pattern to all other supposed objections submitted insofar as it merely states grievances that the class-member has with Defendant U.S. Security. Again, this statement actually appears to support the instant settlement as Ms. Burley would receive compensation for any grievances falling within the purview of this action, while not being subject to a broad general release.. Ms. Burley s objection likewise does not cite any inadequacy with the noticed settlement amount nor the terms of the settlement. Additionally, Ms. Burley s the settlement. Therefore, Ms. Burley s objection does not appear to be a true objection to the settlement.. Class-member Taquesha Lanita White (at C- ) sent a notice of objection dated Oct. th, 0. Ms. White listed her legal basis supporting objection as follows: U.S. Security Associates, they would leave me at my post and most of the time I didn t get a lunch until - hours on the clock, % of the time. They never paid me for all the overtime I did. My supervisor wouldn t turn in my time sheets, so I would have to wait til the following pay period Case No. CV 0-0 PSG(Ex)

6 Case :0-cv-0-PSG-E Document - Filed /0/ Page of Page ID #: 0 0. Ms. White s objection likewise appears to support the instant settlement as, much like Ms. Burley, she would receive compensation for any grievances falling within the purview of this action, while not being subject to a broad general release. Ms. White s objection does not cite any inadequacy with the noticed settlement amount nor the terms of the settlement. Additionally, Ms. White s the settlement. Therefore, Ms. White s objection does not appear to be a true objection to the settlement.. CPT provided my office and the Court with two additional responses to the class notice written by class-members Christina Marie Brown and Lauren A Brown. (at C- and C-, respectively). Although these responses were included in CPT s objection statistics, they do not state any objection whatsoever, nor do they make any reference to the objection procedures in class settlement notice. Instead, these responses simply state that class members Christina and Lauren Brown both intend to appear at the final approval hearing.. Again, these responses do not cite any inadequacy with the noticed settlement amount nor the terms of the settlement. Likewise, they do not call into question the fairness, reasonableness, or adequacy of the settlement. Therefore, these responses do not appear to be objections to the settlement. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed on November, 0, in Agoura Hills, California. s/ Cody R. Kennedy CODY R. KENNEDY, ESQ. Case No. CV 0-0 PSG(Ex)