Contract analysis

1. I am the Vice President of Legal & Compliance at Aurelius Media Americas Inc. ("AMA"), a position I have held since June 2019. In my capacity as Vice President of Legal & Compliance, I am responsible for overseeing AMA's legal affairs, regulatory compliance, and internal policy administration, including matters relating to employment law compliance, corporate governance, and risk management. I make this declaratio

2. AMA is a corporation organized and existing under the laws of the State of Delaware (Delaware Secretary of State File No. 5284731), and is qualified to do business in the State of California. AMA's principal office is located at 8500 Sunset Boulevard, Suite 1400, West Hollywood, California 90069. AMA is a wholly owned subsidiary of Aurelius Global Media Group PLC ("AGMG"), a public limited company organized under

3. AMA employs approximately 3,200 employees in the United States, of whom approximately 2,400 are based in the State of California. AMA operates seven production and office facilities in California, each of which houses various departments, production units, and operational teams: (a) 8500 Sunset Boulevard, Suite 1400, West Hollywood, California 90069, which serves as AMA's corporate headquarters and principal post-

4. AMA maintains comprehensive written policies and procedures regarding employee compensation, including policies governing meal periods, rest periods, overtime compensation, and timekeeping. These policies are set forth in AMA's Employee Handbook, which was most recently revised in March 2021. The Employee Handbook is distributed to all employees at the time of hire, and each employee is required to execute an ackn

5. AMA's written rest period policy, as set forth in Section 5.3 of the Employee Handbook, provides in relevant part: "All non-exempt employees are entitled to a net 10-minute paid rest period for every four (4) hours worked or major fraction thereof. Rest periods shall be scheduled, insofar as practicable, in the middle of each work period." This rest period policy is intended to comply with all applicable provision

6. AMA utilizes the "TimeTrack Pro" electronic timekeeping system developed and licensed by NovaPay Solutions Inc. ("NovaPay"), a payroll and workforce management technology provider headquartered at 2200 Powell Street, Suite 600, Emeryville, California 94608. AMA has used the TimeTrack Pro system continuously since January 1, 2019 for all non-exempt, hourly employees at each of its California facilities. The TimeTra

7. AMA maintains policies and procedures requiring the payment of overtime compensation to all non-exempt employees in accordance with California Labor Code sections 510 and 1194 and all applicable IWC Wage Orders, including Wage Order 12. AMA's overtime policy, as set forth in Section 5.5 of the Employee Handbook, requires payment of overtime at the rate of one and one-half (1.5) times the employee's regular rate of

8. AMA's Human Resources department, under the direction of Senior Vice President Lorraine Okafor, is responsible for ensuring compliance with all applicable federal and state wage-and-hour laws, including the California Labor Code, IWC Wage Orders, and related regulations. Ms. Okafor and her team work collaboratively with my department to review, update, and administer AMA's written employment policies, including th

9. In connection with this declaration, I have reviewed Plaintiffs' Complaint filed in this action, including the Seventh Cause of Action asserted under California Business and Professions Code section 17200 et seq. (the "UCL Claim"). The UCL Claim alleges, in conclusory terms, that AMA's compensation practices constitute "unlawful, unfair, and fraudulent" business practices within the meaning of the Unfair Competiti

10. To my knowledge, AMA has not engaged in any business practice directed at its employees — separate and apart from its payroll, timekeeping, and scheduling policies as described in this declaration — that could be characterized as "unfair" or "fraudulent" within the meaning of California Business and Professions Code section 17200. The alleged injuries to Plaintiffs and the putative class — consisting of unpaid me

11. Based on my review of AMA's employment and payroll records maintained in the ordinary course of business, the putative class in this action consists of approximately 1,850 current and former non-exempt, hourly employees of AMA. The class period as pled in the Complaint runs from November 1, 2018 through the present. All putative class members are or were employees of AMA who were subject to the same written polic