Contract analysis

1. Plaintiffs' Motion for Preliminary Approval of Class Action Settlement;

2. Plaintiffs' Memorandum of Points and Authorities in Support of Motion for Preliminary Approval of Class Action Settlement;

3. Declaration of Renata Vasquez in Support of Preliminary Approval of Class Action Settlement;

4. Declaration of Marco Castellano in Support of Preliminary Approval of Class Action Settlement, including all exhibits attached thereto;

5. The Class Action Settlement Agreement and Release, fully executed on September 15, 2023 (hereinafter, the "Settlement Agreement"), attached as Exhibit 1 to the Motion for Preliminary Approval;

6. The proposed Class Notice (Long Form), attached as Exhibit A to the Settlement Agreement;

7. The proposed Class Notice (Summary/Postcard Form), attached as Exhibit B to the Settlement Agreement; The Court has further considered the arguments of counsel presented at the hearing on this Motion, the entire record in this action, and the applicable law, including the standards set forth in Dunk v. Ford Motor Co. (1996) 48 Cal.App.4th 1794 and Kullar v. Foot Locker Retail, Inc. (2008) 168 Cal.App.4th 116, as w

1. PRELIMINARY APPROVAL OF SETTLEMENT 1.1. The Court hereby grants preliminary approval of the Settlement Agreement between Plaintiffs Marisol Fuentes, Derek Halloran, and Yesenia Padilla, on behalf of themselves and the Settlement Class (as defined below), and Defendant Aurelius Media Americas Inc. ("AMA" or "Defendant"). 1.2. The Court finds, on a preliminary basis and subject to the Final Approval Hearing set fort

2. PROVISIONAL CERTIFICATION OF SETTLEMENT CLASS 2.1. For settlement purposes only, and without prejudice to Defendant's right to contest class certification in the event the Settlement does not receive final approval or is otherwise terminated or voided, the Court provisionally certifies the following Settlement Class: "All current and former non-exempt, hourly employees of Aurelius Media Americas Inc. who worked in

3. APPOINTMENT OF CLASS REPRESENTATIVES 3.1. The Court hereby appoints Marisol Fuentes, Derek Halloran, and Yesenia Padilla as Class Representatives for the Settlement Class. The Court finds, on a preliminary basis, that each Class Representative has claims typical of the Settlement Class, has no disqualifying conflicts of interest with the class, and has demonstrated a willingness and ability to represent the intere

4. APPOINTMENT OF CLASS COUNSEL 4.1. The Court hereby appoints Castellano Byrne & Salas LLP (Marco Castellano, Diane Salas, and Trevor Kim), located at 11755 Wilshire Boulevard, Suite 900, Los Angeles, California 90025, as Lead Class Counsel for the Settlement Class. The Court finds that Lead Class Counsel possess the requisite qualifications, experience, and resources to represent the Settlement Class effectively in

5. APPOINTMENT OF CLAIMS ADMINISTRATOR 5.1. The Court hereby appoints Meridian Settlement Services LLC (Angela Truong, Principal Contact), located at 1600 E. Fourth Street, Suite 240, Santa Ana, California 92701, as the Claims Administrator for the Settlement. 5.2. The Claims Administrator shall perform all duties set forth in the Settlement Agreement, including but not limited to the following: (a) Obtaining from De

6. APPROVAL OF CLASS NOTICE PLAN 6.1. The Court approves the proposed Class Notice Plan as set forth in the Settlement Agreement and finds that it constitutes the best notice practicable under the circumstances and satisfies the requirements of due process, California Rules of Court, Rule 3.766(d), and all other applicable law. 6.2. The proposed Class Notice (Long Form) and Class Notice (Summary/Postcard Form), attac

7. OPT-OUT PROCEDURES 7.1. Any Settlement Class member who wishes to be excluded from the Settlement Class must submit a written request for exclusion (an "Opt-Out Request") to the Claims Administrator at the address specified in the Class Notice, postmarked no later than sixty (60) calendar days after the Notice Date (the "Opt-Out Deadline"). Based on the Notice Date of November 3, 2023, the Opt-Out Deadline is set

8. OBJECTION PROCEDURES 8.1. Any Settlement Class member who does not submit a valid and timely Opt-Out Request and who wishes to object to the Settlement, or to any of its terms, must file a written objection with the Clerk of the Court and serve a copy of the written objection on both Class Counsel and Defendant's counsel (at the addresses specified in Section 16 below) no later than the Opt-Out Deadline, i.e., no

9. SUMMARY OF SETTLEMENT TERMS 9.1. For the information of the Court and the parties, the material financial terms of the Settlement are summarized as follows: 9.2. The Settlement is non-reversionary. The entire Gross Settlement Amount of Fourteen Million Seven Hundred Fifty Thousand Dollars ($14,750,000) shall be distributed or allocated as set forth in the Settlement Agreement. No portion of the Gross Settlement Am

10. RELEASED CLAIMS 10.1. The scope of the release is set forth in Section 7 of the Settlement Agreement and is incorporated herein by reference. The release includes, but is not limited to, all claims, demands, rights, and causes of action, whether known or unknown, arising under or related to the following statutes and legal theories, to the extent they arise from or relate to the facts, acts, transactions, occurre

11. STAY OF PROCEEDINGS 11.1. All proceedings in this action, other than proceedings necessary to carry out, implement, or enforce the terms and conditions of the Settlement Agreement and this Order, are hereby STAYED pending the Final Approval Hearing and until further order of this Court. 11.2. During the pendency of this Order, no Settlement Class member, either directly, representatively, on behalf of any putativ

12. FINAL APPROVAL HEARING 12.1. A Final Approval Hearing is hereby set for February 2, 2024, at 8:30 a.m., in Department 34 of the Superior Court of the State of California, County of Los Angeles — Central District, located at 111 North Hill Street, Los Angeles, California 90012. 12.2. At the Final Approval Hearing, the Court will consider the following matters: (a) Whether the Settlement should be finally approved

13. DEADLINES SUMMARY 13.1. The following schedule of deadlines shall govern the remaining proceedings in this matter: 13.2. The parties and the Claims Administrator shall comply with all deadlines set forth in this Order. In the event any deadline falls on a Saturday, Sunday, or court holiday, the deadline shall be extended to the next court business day.

14. EFFECT OF NON-APPROVAL 14.1. In the event the Court does not grant final approval of the Settlement, or in the event the Settlement is terminated, voided, or otherwise fails to become effective pursuant to the terms of the Settlement Agreement, the following shall apply: (a) This Order shall be vacated and rendered null and void in its entirety, and shall have no further force or effect; (b) The provisional certi

15. RETENTION OF JURISDICTION 15.1. The Court retains exclusive and continuing jurisdiction over this action and over all parties to the Settlement Agreement, including all Settlement Class members who do not submit valid and timely Opt-Out Requests, for the following purposes: (a) Implementing, administering, and enforcing the Settlement Agreement and this Order; (b) Ruling on any motions, disputes, or issues that m

16. COUNSEL IDENTIFICATION 16.1. All papers, correspondence, and communications relating to the Settlement and this Order shall be served on counsel as follows: For Plaintiffs and the Settlement Class: Marco Castellano Castellano Byrne & Salas LLP 11755 Wilshire Boulevard, Suite 900 Los Angeles, California 90025 Telephone: (310) 555-4100 Email: mcastellano@cbsemploymentlaw.com Sandra Higuera Veltrano Employment Law G