Contract analysis

I. INTRODUCTION Defendant Aurelius Media Americas Inc. ("AMA"), by and through its counsel of record, Calderwood & Harkness LLP, hereby submits these evidentiary objections to the Declaration of Dr. Howard Rennick ("Rennick Declaration"), filed by Plaintiffs Marisol Fuentes, Derek Halloran, and Yesenia Padilla (collectively, "Plaintiffs") in support of their Motion for Class Certification. The Rennick Declaration was

II. LEGAL STANDARD FOR EVIDENTIARY OBJECTIONS California Evidence Code section 801, subdivision (b), provides that expert opinion testimony is admissible only when it is "[b]ased on matter (including his special knowledge, skill, experience, training, and education) perceived by or personally known to the witness or made known to him at or before the hearing, whether or not admissible, that is of a type that reasonab

III. OBJECTIONS Objection No. 1 Paragraphs 14–19 and Table 3 of the Rennick Declaration Meal Period Damages Calculation — Assumption That Every Auto-Deducted Meal Period Constitutes a "Missed" Meal Period The Challenged Testimony. In paragraphs 14 through 19 and the accompanying Table 3, Dr. Rennick calculates aggregate first meal period premium damages of approximately $16.3 million for the putative class. The core

IV. CONCLUSION For all of the foregoing reasons, Defendant Aurelius Media Americas Inc. respectfully requests that the Court sustain each of the foregoing seven evidentiary objections and exclude the identified portions of the Declaration of Dr. Howard Rennick from consideration in connection with Plaintiffs' Motion for Class Certification. In the alternative, to the extent the Court declines to exclude any or all of