Contract analysis

1. I am the Director of Production Operations at Aurelius Media Americas Inc. ("AMA"). I have held this position since August 2017. In this capacity, I am responsible for overseeing production operations across all seven of AMA's California production facilities and for coordinating with the Unit Production Managers ("UPMs") and Line Producers who manage each of AMA's fourteen show units. I report directly to AMA's S

2. AMA is a wholly owned subsidiary of Aurelius Global Media Group PLC ("AGMG"), a United Kingdom-headquartered public media, entertainment, and e-commerce conglomerate listed on the London Stock Exchange (LSE: AGMG). AMA is a Delaware corporation qualified to do business in the State of California, with its principal office located at 8500 Sunset Boulevard, Suite 1400, West Hollywood, California 90069. As of the dat

3. AMA operates seven California production facilities. Each facility has a distinct function and supports different types of production activity. The seven facilities are as follows: (a) Facility 1 — West Hollywood (HQ & Post-Production): Located at 8500 Sunset Boulevard, Suite 1400, West Hollywood, California 90069. This facility serves as AMA's corporate headquarters and also houses a significant portion of AMA's

4. During the class period, AMA operated fourteen distinct production units (commonly referred to as "show units") across the seven facilities identified above. Each show unit functions as a semi-autonomous production operation with its own production schedule, dedicated crew, supervisory structure, and operational requirements. The fourteen show units span a wide range of production formats and genres, including stu

5. The decentralized supervisory structure of AMA's production operations is central to understanding why Plaintiffs' claims cannot be adjudicated on a class-wide basis. Each show unit has its own UPM or Line Producer who is responsible for the day-to-day scheduling of work on that show unit, including the scheduling of meal periods and rest periods. AMA provides its UPMs and Line Producers with written guidelines re

6. Several of AMA's fourteen show units are studio-based — that is, they are filmed on controlled sound stages at Facilities 1, 2, or 6. Studio-based shows represent a distinct production environment in which scheduling is relatively predictable and manageable. To illustrate the studio-based production experience, I will describe the operations of "Kitchen Clash," a studio-based culinary competition show filmed at Fa

7. In stark contrast to the studio-based production experience, other AMA show units are field-based, operating at remote or outdoor locations coordinated from Facility 4 in Burbank. The field-based production experience presents fundamentally different scheduling challenges. To illustrate these differences, I will describe the operations of "Summit Challenge," AMA's flagship outdoor adventure competition format. "Su

8. AMA's Live Events Division, headquartered at Facility 4 in Burbank, produces concerts, award shows, and other live programming for broadcast and streaming distribution. Named plaintiff Yesenia Padilla worked as a Segment Coordinator in the Live Events Division at Facility 4 from January 10, 2018 through May 17, 2022. The live events production environment presents its own unique and distinct scheduling constraints

9. AMA's post-production operations are based at Facility 1 (West Hollywood headquarters), Facility 5 (Hollywood), and Facility 7 (El Segundo). Named plaintiff Derek Halloran worked as a Post-Production Assistant at Facility 5 in Hollywood from June 1, 2020 through November 30, 2022. Post-production is an office-based environment consisting of editing bays, audio mixing suites, color correction rooms, and review scre

10. AMA's digital content production operations are based at Facility 3 in Sherman Oaks, and its e-commerce production operations are based at Facility 6 in Santa Monica. These two production environments, while distinct from each other, are also materially different from AMA's larger unscripted, field, and live events show units. Digital content production at Facility 3 operates on a hybrid schedule. On some days, d

11. For every production day across all of AMA's show units, AMA's production department issues a daily call sheet. The call sheet is the primary scheduling document for the production day and is distributed to all crew members in advance — typically the evening before the production day, though on some show units the call sheet is distributed earlier. Each call sheet specifies, among other things: the call time (whe

12. Plaintiffs allege in their operative complaint and in their class certification motion that AMA required its employees to perform "off-the-clock" work before their scheduled clock-in time (what Plaintiffs characterize as "pre-shift setup") and after their scheduled clock-out time (what Plaintiffs characterize as "post-shift wrap"). I am familiar with AMA's policies and practices regarding the recording of work ti

13. The three named Plaintiffs in this consolidated action worked in three entirely different divisions of AMA, at three different facilities, under different supervisors, on different types of productions, during partially overlapping but not identical periods of employment. Their diverse and divergent experiences illustrate the fundamental lack of commonality among the proposed class members. (a) Marisol Fuentes wo

14. In my role as Director of Production Operations, I have personally observed and am familiar with the supervisory practices of the UPMs and Line Producers across all fourteen of AMA's show units. I interact regularly with UPMs and Line Producers through weekly production meetings, periodic site visits to each facility, and daily communication regarding production schedules, budgets, and operational issues. Based o

15. Based on my review of production schedules and TimeTrack Pro data, conducted in consultation with AMA's payroll department and Human Resources department, I can confirm that shift lengths and overtime frequency vary dramatically across AMA's fourteen show units. This variation is directly relevant to the class certification analysis because it demonstrates that the proposed class members do not share a uniform ex

16. Based on my over eighteen years of experience in entertainment production operations and my personal knowledge of AMA's production operations throughout the class period, I can state with confidence that the production environments, scheduling practices, supervisory structures, and meal and rest break experiences across AMA's seven California facilities and fourteen show units are materially different from one an