Contract analysis

1. I am the founding partner of the law firm Castellano Byrne & Salas LLP ("CB&S"), located at 11755 Wilshire Boulevard, Suite 900, Los Angeles, California 90025. I am a member of the California State Bar and have been admitted to practice law in the State of California since 2001. Over the course of more than twenty-two years of legal practice, I have specialized in wage-and-hour class actions and representative act

2. This declaration is submitted in support of Plaintiffs' Motion for Preliminary Approval of the Class Action Settlement reached between the Parties. Set forth below is a summary of the procedural history of this litigation, the extensive investigation and discovery that preceded settlement, the arm's-length negotiations that produced the settlement, and the reasons why Class Counsel believes the settlement is fair,

3. The Consolidated Complaint asserts seven causes of action on behalf of a putative class of approximately 1,850 current and former non-exempt, hourly employees of AMA who worked in the State of California at any time during the class period. As defined in the settlement, the class period runs from November 1, 2018 through October 31, 2023. The seven causes of action are as follows: (1) Failure to provide compliant

4. Before filing the initial complaint, Class Counsel conducted an extensive pre-filing investigation into the factual and legal bases for Plaintiffs' claims. This investigation included the following: (a) Named Plaintiff Interviews. Class Counsel conducted multiple detailed interviews with each of the three named plaintiffs — Marisol Fuentes, Derek Halloran, and Yesenia Padilla — regarding their employment experienc

5. Following the filing of the consolidated action, the parties engaged in extensive formal discovery over a period of approximately eight months, from January 2023 through August 2023. The scope and volume of discovery were substantial, reflecting the complexity of the claims and the size of the putative class. The principal categories of discovery are summarized below. (a) Document Production. AMA produced a total

6. Class Counsel retained Dr. Howard Rennick of Pinnacle Economic Consulting Group LLC (Palo Alto, California) as Plaintiffs' economics and damages expert. Dr. Rennick is a labor economist with over fifteen years of experience in employment litigation matters, with particular expertise in the analysis of timekeeping and payroll data in wage-and-hour class actions. Dr. Rennick submitted his expert report on April 28,

7. On April 14, 2023, Plaintiffs filed their Motion for Class Certification, supported by declarations from the three named plaintiffs, from Dr. Rennick, and from Class Counsel, along with a compendium of exhibits drawn from the discovery record. Plaintiffs sought certification of a class defined to include all current and former non-exempt, hourly employees of AMA who worked in California during the class period and

8. Following entry of the class certification order, the parties promptly turned their attention to settlement discussions. Both sides recognized that the certification order — which certified certain claims but denied others — created a dynamic in which meaningful settlement discussions could be productive, as both sides faced significant risks in the event of continued litigation. The parties agreed to engage in me

9. The material terms of the proposed settlement, as set forth in the Settlement Agreement executed by both parties on September 15, 2023 and attached as Exhibit 1 to the Motion for Preliminary Approval, are summarized below: Gross Settlement Amount. The Gross Settlement Amount ("GSA") is Fourteen Million Seven Hundred Fifty Thousand Dollars ($14,750,000.00). The GSA is non-reversionary — meaning that no portion of t

10. Based on my more than twenty-two years of experience litigating wage-and-hour class actions in California, including successful resolution of more than forty such cases, it is my professional opinion that the proposed settlement is fair, reasonable, and adequate, and that it provides meaningful and substantial relief to the class. The GSA of $14,750,000.00 represents approximately 38.2% of Plaintiffs' expert's to

11. The three named plaintiffs are adequate class representatives who have diligently fulfilled their duties to the class throughout this litigation. Marisol Fuentes is a former Production Coordinator in AMA's Unscripted Programming Division. She was employed at AMA from March 14, 2019 through August 5, 2022, at an hourly rate of $28.50 per hour. Ms. Fuentes worked at AMA's Studio City facility (designated as Facilit

12. CB&S has extensive experience in the prosecution of wage-and-hour class actions and PAGA representative actions in California, with a particular focus on the entertainment and hospitality industries. The firm has been recognized by courts throughout the State as competent and effective class counsel in numerous prior cases, and has obtained substantial recoveries for class members through both settlement and tria

13. Class Counsel proposes Meridian Settlement Services LLC ("Meridian") as the claims administrator for this settlement. Meridian is an experienced class action settlement administration firm based in Santa Ana, California, with extensive experience administering wage-and-hour class action settlements in California. Meridian's principal contact for this matter is Angela Truong, who has overseen the administration of

14. Class Counsel requests an award of attorneys' fees equal to thirty-three and one-third percent (33.33%) of the GSA, totaling $4,916,175.00, plus reimbursement of documented litigation costs in the amount of $412,300.00. A detailed motion for final approval of attorneys' fees, together with supporting declarations, time records, and cost documentation, will be filed in advance of the final approval hearing. At thi

15. The proposed class notice plan has been designed to provide the best practicable notice to all class members, consistent with the requirements of due process and California Rules of Court, rule 3.766. The notice plan includes two components: a long-form notice and a summary postcard notice. The long-form notice provides a comprehensive description of the following information: (a) The nature of the case, includin

16. Class Counsel proposes the following timeline for the remaining proceedings in connection with the settlement: The foregoing timeline is subject to adjustment based on the Court's calendar and the Court's directions at the time of preliminary approval. Class Counsel will work with the claims administrator and with AMA's counsel to ensure that all deadlines are met in a timely manner.

17. For all of the foregoing reasons, Class Counsel respectfully submits that the proposed settlement is fair, reasonable, and adequate and was reached through extensive, arm's-length negotiations facilitated by an experienced retired judicial officer, the Honorable Patricia Okoro (Ret.). The settlement provides substantial and meaningful monetary relief to approximately 1,850 class members, avoids the significant ri