Contract analysis

I. INTRODUCTION Defendant Aurelius Media Americas Inc. ("AMA" or "Defendant") hereby submits the following evidentiary objections to the declarations of named plaintiffs Marisol Fuentes ("Fuentes"), Derek Halloran ("Halloran"), and Yesenia Padilla ("Padilla") (collectively, the "Named Plaintiffs"), each filed on April 14, 2023, in support of Plaintiffs' Motion for Class Certification (the "Motion"). These objections

II. LEGAL STANDARDS GOVERNING EVIDENTIARY OBJECTIONS The following legal standards govern the admissibility of the challenged testimony in the Named Plaintiffs' declarations. A. Personal Knowledge (Evid. Code § 702) California Evidence Code section 702, subdivision (a), provides that "[t]he testimony of a witness concerning a particular matter is inadmissible unless he has personal knowledge of the matter." A declara

III. OBJECTIONS TO DECLARATION OF MARISOL FUENTES For context, the Court should be aware of the following undisputed facts relevant to the scope and weight of Fuentes's declaration: • Fuentes was employed by AMA as a Production Coordinator in the Unscripted Programming Division at AMA's Studio City facility, located at 4024 Penmark Strategy Partners Avenue, Studio City, California 91604, designated in the record as "

IV. OBJECTIONS TO DECLARATION OF DEREK HALLORAN For context, the Court should be aware of the following undisputed facts relevant to the scope and weight of Halloran's declaration: • Halloran was employed by AMA as a Post-Production Assistant in the Digital Content Division at AMA's Hollywood facility, located at 1438 N. Gower Street, Hollywood, California 90028, designated in the record as "Facility 5." • Halloran's

V. OBJECTIONS TO DECLARATION OF YESENIA PADILLA For context, the Court should be aware of the following undisputed facts relevant to the scope and weight of Padilla's declaration: • Padilla was employed by AMA as a Segment Coordinator in the Live Events Division at AMA's Burbank facility, located at 3800 W. Alameda Avenue, Burbank, California 91505, designated in the record as "Facility 4." • Padilla's employment wit

VI. GENERAL OBJECTIONS APPLICABLE TO ALL THREE DECLARATIONS In addition to the specific objections set forth above, AMA asserts the following objections that apply to all three declarations. Objection No. 17 Objected-to Statements: Fuentes Declaration, ¶¶ 34–35; Halloran Declaration, ¶¶ 29, 31; Padilla Declaration, ¶¶ 33, 35–36. Each declarant states, in substance, that her experience is "typical" of all class member

VII. REQUEST For the foregoing reasons, Defendant Aurelius Media Americas Inc. respectfully requests that the Court:

1. Sustain each of the foregoing eighteen evidentiary objections (Objection Nos. 1 through 18);

2. Exclude and disregard the identified statements in the declarations of Marisol Fuentes, Derek Halloran, and Yesenia Padilla in ruling on Plaintiffs' Motion for Class Certification; and

3. Consider these objections in connection with AMA's Opposition to Motion for Class Certification, Memorandum of Points and Authorities in Opposition, and supporting declarations and exhibits, all filed concurrently herewith. Dated: June 16, 2023 CALDERWOOD & HARKNESS LLP By: ________ Devon Archer (SBN 301462) Renata Vasquez (SBN 224578) Devon Archer (SBN 301462) 777 South Flower Street, Suite 4200 Los Angeles, Cali