Contract analysis

1. Scope of Engagement You are retained to serve as an economics and damages expert for the defense of AMA in this matter. The engagement encompasses the following specific areas of analysis and opinion: (a) Rebuttal of Plaintiffs' Damages Model. You will analyze and rebut the damages model anticipated to be presented by Plaintiffs' retained expert, Dr. Howard Rennick of Pinnacle Economic Consulting Group LLC, locate

2. Compensation Hargrove Analytics Inc. will be compensated for professional services rendered in connection with this engagement at the following hourly rates: All time shall be recorded and billed in increments of one-tenth of an hour (0.1 hours), with a brief description of the task performed for each time entry. Invoices shall be submitted on a monthly basis to Calderwood & Harkness LLP, directed to the attention

3. Materials to Be Provided C&H will provide the following materials for your review and analysis in connection with this engagement:

1. NovaPay Solutions TimeTrack Pro Timekeeping Data. Complete timekeeping data for all AMA non-exempt California employees for the class period (November 1, 2018 to present), including raw punch records, auto-deduction records, and Missed Meal Attestation records, organized by facility. This data will be produced in a format compatible with standard statistical and econometric analysis software.

2. Payroll Records and Wage Statements. Payroll records and itemized wage statements for the putative class members, as extracted from the NovaPay Solutions system, covering the full class period.

3. AMA Meal and Rest Break Policies. AMA's meal and rest break policies, including the current employee handbook (March 2021 revision) and the prior Meal and Rest Break Policy (dated January 2019), together with any amendments or supplemental guidance documents issued during the class period.

4. TimeTrack Pro System Configuration Records. System configuration records for the TimeTrack Pro timekeeping system, including auto-deduction threshold settings (which were set at six hours throughout the majority of the class period and corrected to five hours in December 2022), as well as activation and deactivation logs for the Missed Meal Attestation feature by facility. We note that, during the relevant period,

5. Plaintiffs' Class Certification Motion. Plaintiffs' motion for class certification and all supporting declarations, exhibits, and memoranda of points and authorities, which are anticipated to be filed on or about April 14, 2023.

6. Plaintiffs' Expert Report. The expert report of Dr. Howard Rennick, Pinnacle Economic Consulting Group LLC, which is anticipated to be served on or about April 28, 2023, together with all supporting data, analyses, and appendices.

7. Deposition Transcripts. Transcripts of depositions of named plaintiffs Marisol Fuentes, Derek Halloran, and Yesenia Padilla, as well as depositions of AMA corporate witnesses and any other witnesses, as they become available during the course of discovery.

8. Co-Expert Report and Declaration. The expert report and declaration of Dr. Rajesh Makhija of Workforce Dynamics Consulting LLC, who has been separately retained as a defense industrial/organizational expert. This material is provided for coordination purposes, as described in Section 5 below.

9. AMA Operational Records. AMA's production schedules, show unit information, and facility operational profiles for each of its seven California production facilities and the fourteen show units currently operating under IWC Wage Order 12, to the extent relevant to your analysis of commonality and individualized damages issues.

10. PAGA Notice and Correspondence. The PAGA notice submitted to the California Labor and Workforce Development Agency ("LWDA") dated September 15, 2022, together with all related correspondence and filings. Additional materials may be provided as discovery progresses and as additional documents or data become available. If, during the course of your analysis, you identify additional categories of data or documents t

4. Deliverables and Timeline The following deliverables and target dates have been established for this engagement, subject to adjustment as circumstances warrant: Please note that the Initial Review and Preliminary Assessment Memorandum is intended solely for internal use by the defense team and will not be filed with the Court. It should provide a preliminary overview of the available data, initial observations reg

5. Coordination with Co-Expert Your work on this engagement will be coordinated with the work of Dr. Rajesh Makhija of Workforce Dynamics Consulting LLC, located at 444 Castro Street, Suite 800, Mountain View, California 94041. Dr. Makhija has been separately retained by C&H as an industrial/organizational expert to opine on the variability of working conditions, meal break practices, scheduling protocols, and superv

6. Confidentiality All materials provided to you in connection with this engagement are confidential and are subject to the Stipulated Protective Order entered in this case on February 15, 2023 (the "Protective Order"). The Protective Order establishes two tiers of confidentiality protection: CONFIDENTIAL and HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY. You should be aware that certain categories of data and documents

7. Communication Protocol To ensure the efficient and orderly management of this engagement, all substantive communications regarding the engagement should be directed to the following members of the C&H defense team: Primary Day-to-Day Contact: Devon Archer, Senior Associate Calderwood & Harkness LLP Telephone: (213) 555-7238 Email: darcher@calderwoodharkness.com Strategic and High-Level Matters: Renata Vasquez, Par

8. Retention of Work Papers You should retain all work papers, data files, notes, drafts, and communications related to this engagement throughout the pendency of the litigation and for a reasonable period thereafter. These materials may be subject to discovery requests or deposition inquiry, and their availability may be important to the defense's ability to support and defend your expert opinions. Work papers shoul

9. Disclosures and Prior Engagements You should promptly disclose to C&H any prior engagement or professional relationship involving any party to this litigation (including AMA, the named plaintiffs, or any related entities), any attorney of record (including counsel for Plaintiffs), or any other individual or entity whose involvement in this matter could give rise to a conflict of interest or an appearance of bias.

10. Termination Either party may terminate this engagement at any time upon written notice to the other party. In the event of termination, Hargrove Analytics Inc. will be compensated for all professional fees earned and expenses incurred through the date of termination, in accordance with the compensation terms set forth in Section 2 above. Upon termination, all materials provided by C&H to you or your staff in conn