Contract analysis

I. DEPOSITION LOGISTICS Deponent: Yesenia Padilla Date: May 16, 2023 Time: 9:30 a.m. Location: Offices of Calderwood & Harkness LLP, 777 South Flower Street, Suite 4200, Los Angeles, California 90017 Estimated Duration: The deposition is expected to last up to seven (7) hours of testimony, in accordance with the presumptive limit set forth in California Code of Civil Procedure section 2025.290, subdivision (a). The s

II. SUBJECT MATTERS TO BE EXAMINED The deposition of Yesenia Padilla will cover the following subject matters. This list is illustrative and not exhaustive. Defendant reserves the right to examine the Deponent on any matter relevant to the subject action or reasonably calculated to lead to the discovery of admissible evidence, consistent with the California Code of Civil Procedure and applicable law.

1. Employment History with AMA The deposition will cover Padilla's complete employment history with Aurelius Media Americas Inc., including but not limited to: (a) Her date of hire, which AMA records reflect as January 10, 2018; (b) Her date of separation from employment, which AMA records reflect as May 17, 2022; (c) Her title during her employment, including her most recent title of Segment Coordinator within AMA's

2. Work Schedules and Shift Patterns The deposition will cover the following topics related to Padilla's work schedules and shift patterns during her employment with AMA: (a) Her typical work schedules, including her regular start times, end times, and shift lengths; (b) The frequency and duration of production days versus office or preparation days, and how the allocation between these categories of workdays varied

3. Meal Period Experiences The deposition will cover the following topics related to Padilla's personal experiences with meal periods during her employment with AMA: (a) Whether she received compliant, uninterrupted, thirty (30)-minute, duty-free meal periods during her shifts, as required under California law; (b) The frequency with which she alleges that meal periods were missed, shortened, interrupted, or not prov

4. Rest Period Experiences The deposition will cover the following topics related to Padilla's experiences with rest periods during her employment with AMA: (a) Whether she was authorized and permitted to take ten (10)-minute paid rest periods for every four (4) hours worked, or major fraction thereof, in accordance with California law; (b) The frequency with which rest periods were allegedly missed, shortened, or de

5. Timekeeping Practices and the TimeTrack Pro System The deposition will cover the following topics related to timekeeping practices and the NovaPay Solutions "TimeTrack Pro" electronic timekeeping system used by AMA: (a) Padilla's familiarity with and use of the TimeTrack Pro electronic timekeeping system, including when she first began using the system and the frequency with which she interacted with it; (b) Her c

6. Off-the-Clock Work Allegations The deposition will cover the following topics related to Padilla's allegations of off-the-clock work during her employment with AMA: (a) Whether Padilla performed work before her official clock-in time or after her official clock-out time, and if so, the frequency with which such work was allegedly performed; (b) The nature and duration of any alleged pre-shift setup work, including

7. Complaints and Grievances The deposition will cover the following topics related to complaints or grievances raised by Padilla during her employment with AMA: (a) Whether Padilla ever filed a formal or informal complaint with AMA's Human Resources department, any supervisor, any manager, or any other person regarding meal periods, rest periods, overtime, off-the-clock work, or any other wage-and-hour issue; (b) Th

8. Knowledge of Other Employees' Experiences The deposition will cover the following topics related to Padilla's knowledge of the experiences of other putative class members: (a) The basis for any statements or allegations in the operative complaint regarding the experiences of other putative class members, including whether such statements are based on personal knowledge, hearsay, or information provided by counsel;

9. Relationship with Counsel and Initiation of Litigation The deposition will cover the following topics related to Padilla's relationship with her counsel and the initiation of this litigation: (a) How Padilla came to be represented by Castellano Byrne & Salas LLP and/or Veltrano Employment Law Group PC; (b) When she first contacted or was contacted by Plaintiffs' counsel, and the circumstances of that initial conta

10. Adequacy and Typicality as Class Representative The deposition will cover the following topics related to Padilla's adequacy and typicality as a putative class representative: (a) Whether she believes her experiences as a Segment Coordinator in the Live Events Division at the Burbank facility are representative of all non-exempt, hourly employees across AMA's seven (7) California production facilities and fourtee

11. Damages. The deposition will cover the following topics related to Padilla's claimed damages: (a) Her individual calculation or estimate of damages, including the factual and mathematical basis for that calculation; (b) Wages she alleges she was not paid, including but not limited to meal period premiums, rest period premiums, overtime compensation, and minimum wage shortfalls; (c) The time period over which she

12. AMA Policies and Training The deposition will cover the following topics related to AMA policies and training received by Padilla: (a) Her receipt and review of the AMA Employee Handbook, including the version revised in March 2021; (b) Whether she signed an acknowledgment of receipt of the handbook or any AMA policies, including any policies relating to meal periods, rest periods, overtime, timekeeping, or wage-

13. Documents. The deposition will cover the following topics related to documents in Padilla's possession, custody, or control: (a) Identification of all documents in Padilla's possession, custody, or control that relate to her employment with AMA, her work schedule, her meal and rest period experiences, her off-the-clock work, or any other issue in this litigation; (b) Any personal calendars, journals, notebooks, o

III. REQUEST TO PRODUCE DOCUMENTS AT DEPOSITION Pursuant to California Code of Civil Procedure section 2025.280, subdivision (a), Deponent Yesenia Padilla is hereby requested to bring to the deposition the following documents:

1. All documents responsive to Defendant AMA's First Set of Requests for Production of Documents to Plaintiff Yesenia Padilla (Request Nos. 1 through 20), served on February 24, 2023, to the extent such documents have not already been produced as of the date of the deposition.

2. Any additional responsive documents identified, located, or obtained after the date of Deponent's initial production in response to the First Set of Requests for Production.

3. Any documents that Deponent intends to refer to, rely upon, or use in any way during the deposition to refresh her recollection or support her testimony.

IV. LEGAL AUTHORITIES This deposition is noticed and will be taken pursuant to California Code of Civil Procedure sections 2025.010 through 2025.620. The duration of the deposition shall not exceed seven (7) hours of testimony, in accordance with California Code of Civil Procedure section 2025.290, subdivision (a). The Deponent is reminded of her obligations under California Code of Civil Procedure section 2025.480 r

V. MEET AND CONFER / SCHEDULING Defense counsel recognizes the importance of cooperative scheduling and is available to discuss alternative dates or reasonable scheduling accommodations. If the noticed date of May 16, 2023, is not available for the Deponent or for Plaintiffs' counsel, Defendant respectfully requests that Plaintiffs' counsel contact Devon Archer at Calderwood & Harkness LLP at (213) 555-7238 or darche