Contract analysis

1. I am the Principal Contact at Meridian Settlement Services LLC ("Meridian"), a California limited liability company that provides settlement administration services in class action, collective action, and mass tort litigation throughout the United States. Meridian's principal office is located at 1600 E. Fourth Street, Suite 240, Santa Ana, California 92701. Meridian was appointed as the Claims Administrator in th

2. Meridian Settlement Services LLC was retained to administer the class action settlement in this action. The settlement arises out of a Settlement Agreement and Release (the "Settlement Agreement") executed on September 15, 2023, between Plaintiffs Marisol Fuentes, Derek Halloran, and Yesenia Padilla, on behalf of themselves and the settlement class, and Defendant Aurelius Media Americas Inc. ("AMA"). The Settlemen

3. The settlement class, as defined in the Preliminary Approval Order, consists of: "All current and former non-exempt, hourly employees of Aurelius Media Americas Inc. who worked in the State of California at any time from November 1, 2018 through October 31, 2023, who were subject to AMA's automatic meal period deduction in the NovaPay Solutions TimeTrack Pro timekeeping system." The estimated size of the settlemen

4. Meridian received the class list from AMA on October 25, 2023. The class list contained 1,850 individual names together with corresponding employment and contact data as described above. Upon receipt of the class list, Meridian performed its standard verification procedures to ensure the accuracy of mailing addresses. Specifically, Meridian processed all 1,850 addresses through the National Change of Address ("NCO

5. Consistent with the Preliminary Approval Order, Meridian mailed class notice to all identified class members on November 3, 2023. A total of 1,843 individual notice packages were mailed via first-class United States mail on that date. Each notice package contained two forms of notice, as approved by the Court: (a) A long-form class notice, consisting of a four-page, plain-language document printed on letter-sized

6. Of the 1,843 notices mailed on November 3, 2023, a total of seven (7) were returned by the United States Postal Service as undeliverable. Upon receipt of each returned notice, Meridian performed additional skip-trace research using the commercial locate database to obtain updated mailing addresses for the affected class members. Meridian was successful in obtaining updated addresses for all seven (7) individuals w

7. In addition to the mailed notices, Meridian established and maintained a dedicated settlement website to provide class members with access to information about the settlement and a convenient means of submitting claims online. The settlement website was activated on November 3, 2023, the same date as the initial notice mailing, and has remained continuously accessible at all times since activation. The website con

8. Meridian also established a dedicated toll-free telephone number for class members to call with questions about the settlement. The toll-free telephone line was activated on November 3, 2023, concurrent with the notice mailing and website activation. The telephone line provided pre-recorded information about the settlement in both English and Spanish, including a summary of the settlement terms, the claims deadlin

9. The claims period opened on November 3, 2023, coinciding with the date of notice mailing. Class members were provided three methods for submitting their claims: (a) Online: Through the online claim submission portal accessible on the settlement website, using a unique claim identification number assigned to each class member; (b) Mail: By completing and returning the paper claim form included with the long-form cl

10. Class members who wished to exclude themselves from the settlement class were required to submit a written opt-out request, postmarked or received by Meridian on or before January 2, 2024. Opt-out requests were required to include the class member's name, address, and a clear statement that the individual wished to be excluded from the settlement in Fuentes, et al. v. Aurelius Media Americas Inc., Case No. 22STCV

11. Class members who wished to object to the settlement were required to submit a written objection, postmarked or received by Meridian on or before January 2, 2024. As of the close of the objection period, Meridian received a total of four (4) written objections. The substance of each objection is summarized below: (a) Carlos Vega (former production assistant at AMA's Burbank facility): Mr. Vega objects to the atto

12. Pursuant to the terms of the Settlement Agreement, the Gross Settlement Amount of $14,750,000.00 is allocated as follows: The Net Settlement Fund of $8,251,525.00 will be distributed to those class members who submitted valid and timely claims and who did not opt out of the settlement. The individual settlement payment for each eligible class member will be calculated according to the allocation formula set forth

13. Per Section 10.5 of the Settlement Agreement, any settlement checks that remain uncashed one hundred eighty (180) days after the date of issuance will be voided by Meridian. Any residual funds resulting from uncashed checks will not revert to AMA but will instead be donated, as a cy pres distribution, to the Legal Aid Foundation of Los Angeles, which was designated as the cy pres recipient in the Settlement Agree

14. Based on the foregoing, Meridian has performed all duties required of it under the Preliminary Approval Order dated October 18, 2023, including, without limitation: (a) Timely mailing of class notices to all identified class members, completed on November 3, 2023, within the deadline established by the Court; (b) Re-mailing of all returned notices after performing skip-trace research, within five (5) business day

15. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on January 22, 2024, in Santa Ana, California. ________________________________________ Angela Truong Principal Contact Meridian Settlement Services LLC 1600 E. Fourth Street, Suite 240 Santa Ana, California 92701 INDEX OF EXHIBITS MARISOL FUENTES, DEREK HALLORAN, and YESENIA PADILLA, indi