1017-00004 · Entities. Aurelius Global Media Group · Discovery/Class Action

ama-rfp-to-fuentes.docx DOCUMENT Finance & Banking

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES — CENTRAL DISTRICT

PRELIMINARY STATEMENT

Defendant Aurelius Media Americas Inc. ("AMA"), by and through its counsel of record, Calderwood & Harkness LLP, hereby propounds its First Set of Requests for Production of Documents (Nos. 1 through 20) to Plaintiff Marisol Fuentes ("Plaintiff" or "Fuentes") pursuant to California Code of Civil Procedure sections 2031.010 through 2031.060.

Plaintiff is required to serve written responses to these Requests within thirty (30) days of service hereof, or within such extended time as may be agreed to by stipulation of the parties, in accordance with California Code of Civil Procedure section 2031.030. Service of these Requests is made by electronic means pursuant to California Code of Civil Procedure section 1010.6, and accordingly the time for response is extended by two (2) court days as provided by California Code of Civil Procedure section 1010.6(a)(4)(A).

These Requests seek production of documents relevant to Plaintiff Fuentes's individual claims as alleged in the Consolidated Complaint filed in this action, Case No. 22STCV38214, including her First through Eighth Causes of Action for (1) failure to pay overtime wages, (2) failure to provide meal periods, (3) failure to provide rest periods, (4) failure to pay minimum wages, (5) failure to furnish accurate itemized wage statements, (6) failure to timely pay all wages due upon separation, (7) unfair business practices under Business and Professions Code section 17200 et seq., and (8) civil penalties under the Private Attorneys General Act, Labor Code section 2698 et seq. These Requests further seek documents relevant to Plaintiff's adequacy and typicality as a putative class representative, and to the merits and damages of the claims asserted on behalf of the putative class of current and former non-exempt, hourly employees of AMA who worked in the State of California at any time during the Class Period.

AMA reserves the right to propound additional discovery requests as permitted by the California Code of Civil Procedure and the California Rules of Court.

DEFINITIONS

As used in these Requests for Production, the following terms shall have the meanings set forth below:

1. "PLAINTIFF" or "YOU" shall mean Marisol Fuentes, individually and in her capacity as a putative class representative in this action, including all agents, attorneys, representatives, accountants, consultants, investigators, and any other person or entity acting on her behalf or at her direction.

2. "AMA" or "DEFENDANT" shall mean Aurelius Media Americas Inc., a Delaware corporation, including its parent entity Aurelius Global Media Group PLC, and all subsidiaries, affiliates, divisions, predecessors, successors, officers, directors, employees, agents, and representatives of any of the foregoing, whether past or present.

3. "DOCUMENT" or "DOCUMENTS" shall have the broadest definition permitted under California Code of Civil Procedure section 2031.010(a) and shall include all writings, recordings, photographs, and electronically stored information ("ESI") of every kind and description, whether originals or copies, and regardless of origin, authorship, or custodian. Without limiting the generality of the foregoing, "DOCUMENT" or "DOCUMENTS" includes but is not limited to: emails, text messages, instant messages (including messages sent or received via Meridian Solutions, Northgate Data Systems, Meridian Services Inc., Westmark Software, Harborline Technologies, Kestrel Data Systems, and any other messaging platform), social media posts, comments, and messages (including those on Kestrel Services Inc., Northpoint Services Inc., Ashford Systems, Dunmore & Co., Westmark Health IT, Reddit, Snapchat, and any other social media platform), letters, memoranda, notes (including handwritten notes), calendars, diaries, journals, logs, spreadsheets, databases, presentations, reports, summaries, analyses, photographs, videos, audio recordings, voicemails, transcripts, contracts, agreements, receipts, invoices, financial records, tax returns, pay stubs, wage statements, and any other tangible or electronically stored thing capable of being reproduced in tangible form.

4. "COMMUNICATION" shall mean every manner or means of disclosure, transfer, or exchange of information, whether oral, written, or electronic, including but not limited to letters, emails, text messages, instant messages, telephone calls, voicemails, video calls, meetings, conversations, and social media interactions, and shall include both the content of the communication and any documents reflecting, summarizing, or memorializing such communication.

5. "RELATING TO" or "CONCERNING" shall mean referring to, describing, evidencing, constituting, mentioning, reflecting, pertaining to, connected with, commenting on, regarding, discussing, analyzing, summarizing, or having any logical relationship to the subject matter referenced.

6. "CLASS PERIOD" shall mean November 1, 2018 through the present, as alleged in the Consolidated Complaint filed in this action.

7. "PUTATIVE CLASS MEMBERS" shall mean all 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 by the putative class alleged in the Consolidated Complaint.

8. "PERSON" shall mean any natural person, corporation, partnership, limited liability company, joint venture, association, trust, governmental entity, or any other legal entity or organization.

9. "EMPLOYMENT PERIOD" shall mean the period of Plaintiff Fuentes's employment with AMA, specifically from March 14, 2019 through August 5, 2022, inclusive.

INSTRUCTIONS

The following instructions apply to each of the Requests for Production set forth below:

1. Scope of Production. Each Request calls for all responsive Documents in Plaintiff's possession, custody, or control. The term "possession, custody, or control" shall be interpreted in accordance with California Code of Civil Procedure section 2031.010 et seq. and applicable case law, and includes Documents held by Plaintiff's attorneys, agents, representatives, accountants, consultants, investigators, or any other person or entity on Plaintiff's behalf, or that are otherwise obtainable by Plaintiff upon demand or request.

2. Electronically Stored Information. These Requests expressly encompass electronically stored information in all forms, media, and formats, including but not limited to emails, text messages, instant messages, social media content (posts, messages, stories, comments, and any other content), documents created in or stored on personal computers, laptops, tablets, smartphones, external hard drives, USB drives, cloud storage services (including but not limited to Hollowell Health IT, Larkspur Technologies, Meridian Systems, Cobalt Ridge Systems, box, and any similar service), backup media, and any other electronic storage medium. To the extent Plaintiff maintains or has maintained multiple email accounts, text messaging accounts, or social media accounts, these Requests extend to all such accounts.

3. Time Period. Unless otherwise stated in a particular Request, each Request covers the period from November 1, 2018 through the date of Plaintiff's response to these Requests. Where a Request references the "EMPLOYMENT PERIOD," the applicable time period is March 14, 2019 through August 5, 2022, as defined above.

4. Privilege Log. If any Document responsive to any Request is withheld, in whole or in part, on the basis of any claim of privilege (including but not limited to the attorney-client privilege, the work product doctrine, or any other statutory or common law privilege), Plaintiff shall identify each such Document on a privilege log in compliance with California Code of Civil Procedure section 2031.240(b). The privilege log shall contain sufficient information to permit assessment of the privilege claim, including at a minimum: (a) the date of the Document; (b) the identity of the author or sender; (c) the identity of all recipients (including "cc" and "bcc" recipients); (d) a description of the type of Document (e.g., email, memorandum, letter); (e) the subject matter of the Document described in sufficient detail to permit an assessment of the privilege claim without revealing the privileged content; and (f) the specific privilege or protection asserted (e.g., attorney-client privilege, attorney work product).

5. Organization of Production. Documents produced in response to these Requests shall be produced either (a) as they are kept in the ordinary course of business, or (b) organized and labeled to correspond with the categories in these Requests, in accordance with California Code of Civil Procedure section 2031.280. If Documents are produced as they are kept in the ordinary course of business, Plaintiff shall identify the particular Request or Requests to which each Document or set of Documents is responsive.

6. Protective Order. Documents produced in response to these Requests may be designated by either party pursuant to the Stipulated Protective Order entered in this action by the Court on February 15, 2023. To the extent Plaintiff believes any responsive Document contains confidential personal information that warrants designation under the Protective Order, Plaintiff is instructed to produce such Document with the appropriate confidentiality designation rather than withholding production entirely.

7. Continuing Duty to Supplement. To the extent Plaintiff discovers, obtains, or becomes aware of additional Documents responsive to these Requests after serving her initial responses, Plaintiff is obligated to supplement or amend her responses in accordance with California Code of Civil Procedure section 2031.050 and any applicable Court orders.

REQUESTS FOR PRODUCTION OF DOCUMENTS

REQUEST FOR PRODUCTION NO. 1

All DOCUMENTS reflecting, constituting, or relating to PLAINTIFF's employment with AMA, including but not limited to offer letters, employment agreements, amendments or addenda to any employment agreement, acknowledgment forms, confidentiality agreements, non-disclosure agreements, arbitration agreements, at-will employment acknowledgments, performance evaluations, performance improvement plans, commendations, disciplinary records, warnings (whether verbal or written), counseling memoranda, separation documents, exit interview records, resignation letters, termination notices, and any other personnel-related documents in PLAINTIFF's possession, custody, or control.

REQUEST FOR PRODUCTION NO. 2

All DOCUMENTS reflecting PLAINTIFF's work schedule during the EMPLOYMENT PERIOD, including but not limited to personal calendars (whether paper or electronic, including but not limited to Brightmoor Services Inc., Tidewater Industries Calendar, Ridgeline Services Inc., or any other calendar application), daily planners, scheduling apps or tools, shift schedules, call sheets, production schedules, and any other records reflecting PLAINTIFF's daily, weekly, or monthly work hours, expected start and end times, or scheduled work days at AMA.

REQUEST FOR PRODUCTION NO. 3

All DOCUMENTS reflecting PLAINTIFF's actual hours worked during the EMPLOYMENT PERIOD, including but not limited to personal logs, diaries, journals, timesheets, time records, notes, spreadsheets, calculations, or any other record — whether contemporaneous or reconstructed at any time — of PLAINTIFF's clock-in times, clock-out times, start times, end times, total hours worked, or overtime hours worked on any given day or week during the EMPLOYMENT PERIOD. This Request includes, without limitation, any personal records maintained by PLAINTIFF separate from or in addition to AMA's NovaPay Solutions "TimeTrack Pro" electronic timekeeping system, as well as any copies of TimeTrack Pro records in PLAINTIFF's possession, custody, or control.

REQUEST FOR PRODUCTION NO. 4

All DOCUMENTS reflecting or relating to meal periods taken or not taken by PLAINTIFF during the EMPLOYMENT PERIOD, including but not limited to personal notes, diaries, logs, calendars, journals, text messages, emails, instant messages, photographs, or any other record reflecting:

(a) the time at which PLAINTIFF began and ended meal periods on any given day;

(b) whether PLAINTIFF was relieved of all duties during meal periods;

(c) whether PLAINTIFF's meal periods were interrupted, shortened, delayed, or missed entirely, and the circumstances of any such interruption, shortening, delay, or missed meal period;

(d) any complaints, grievances, or reports made by PLAINTIFF to any PERSON — including but not limited to any AMA supervisor, manager, human resources representative, or coworker — regarding meal periods; and

(e) any DOCUMENTS reflecting the frequency with which PLAINTIFF alleges she received or did not receive a compliant thirty (30)-minute uninterrupted meal period.

REQUEST FOR PRODUCTION NO. 5

All DOCUMENTS reflecting or relating to rest periods taken or not taken by PLAINTIFF during the EMPLOYMENT PERIOD, including but not limited to personal notes, diaries, logs, calendars, journals, text messages, emails, instant messages, or any other record reflecting:

(a) whether PLAINTIFF received a net ten (10)-minute rest period for every four (4) hours worked or major fraction thereof;

(b) whether rest periods were interrupted, shortened, delayed, or missed, and the circumstances of any such interruption, shortening, delay, or missed rest period;

(c) any complaints, grievances, or reports made by PLAINTIFF to any PERSON — including but not limited to any AMA supervisor, manager, human resources representative, or coworker — regarding rest periods; and

(d) any DOCUMENTS reflecting the frequency with which PLAINTIFF alleges she received or did not receive a compliant ten (10)-minute rest period.

REQUEST FOR PRODUCTION NO. 6

All DOCUMENTS reflecting or relating to any work performed by PLAINTIFF before clocking in or after clocking out (i.e., alleged "off-the-clock" work) during the EMPLOYMENT PERIOD, including but not limited to personal notes, diaries, logs, journals, text messages, emails, instant messages, photographs, or any other record describing the nature, duration, frequency, and circumstances of such off-the-clock work. This Request includes, without limitation, any DOCUMENTS reflecting pre-shift setup activities, post-shift wrap-up activities, or any other work-related tasks performed by PLAINTIFF outside of her recorded clock-in and clock-out times as reflected in AMA's NovaPay Solutions "TimeTrack Pro" electronic timekeeping system.

REQUEST FOR PRODUCTION NO. 7

All pay stubs, wage statements, pay advices, earnings statements, and similar DOCUMENTS received by PLAINTIFF from AMA during the EMPLOYMENT PERIOD and upon separation from employment, including but not limited to PLAINTIFF's final paycheck and any documentation of final wages, any documentation of accrued but unused vacation or paid time off paid out upon separation, any direct deposit confirmations or bank records reflecting receipt of wages from AMA, and any DOCUMENTS reflecting PLAINTIFF's pay rate, hourly wage, bonus payments, or other compensation received from AMA at any time during the EMPLOYMENT PERIOD.

REQUEST FOR PRODUCTION NO. 8

All DOCUMENTS constituting, reflecting, or relating to any complaint, grievance, report, concern, or objection made by PLAINTIFF — whether formal or informal, written or oral, contemporaneous or after the fact — to any AMA supervisor, manager, team lead, department head, human resources representative, or any other AMA employee or representative regarding any of the following:

(a) meal periods;

(b) rest periods;

(d) hours worked or scheduling;

(e) off-the-clock work or unrecorded work time;

(f) wages, pay, or compensation;

(g) timekeeping, time clocks, or AMA's NovaPay Solutions "TimeTrack Pro" system;

(h) any other working condition, labor law compliance matter, or employment practice at issue in this lawsuit; or

(i) any response, acknowledgment, or action taken by AMA or any AMA employee in response to any such complaint, grievance, report, concern, or objection.

REQUEST FOR PRODUCTION NO. 9

All COMMUNICATIONS between PLAINTIFF and any current or former AMA employee (including but not limited to any PUTATIVE CLASS MEMBER) concerning any of the following:

(a) meal periods at AMA;

(b) rest periods at AMA;

(d) hours worked or work schedules at AMA;

(e) off-the-clock work or unrecorded work time at AMA;

(f) wages, pay, compensation, or benefits at AMA;

(g) timekeeping, time clocks, or AMA's NovaPay Solutions "TimeTrack Pro" system;

(h) any other working condition at issue in this lawsuit;

(i) this lawsuit, any prior or related litigation, or any potential claims against AMA; or

(j) the decision by any current or former AMA employee to participate in, join, opt into, or serve as a representative in this lawsuit or any similar legal action against AMA.

REQUEST FOR PRODUCTION NO. 10

All COMMUNICATIONS between PLAINTIFF and any attorney or law firm (including but not limited to Castellano Byrne & Salas LLP, Veltrano Employment Law Group PC, Marco Castellano, Diane Salas, Trevor Kim, Sandra Higuera, or any other attorney, law firm, or legal services provider) concerning this lawsuit, PLAINTIFF's employment with AMA, or any of the claims alleged in the Consolidated Complaint, from the earliest date of any such communication through the present. This Request expressly seeks pre-engagement communications between PLAINTIFF and any attorney or law firm that preceded the formation of an attorney-client relationship, including but not limited to any initial inquiry, solicitation, advertisement, intake communication, or preliminary consultation. To the extent PLAINTIFF withholds any post-engagement communications on the basis of attorney-client privilege or work product protection, PLAINTIFF is instructed to identify such communications on a privilege log in compliance with the Instructions set forth above and California Code of Civil Procedure section 2031.240(b).

REQUEST FOR PRODUCTION NO. 11

All DOCUMENTS reflecting, constituting, or relating to PLAINTIFF's decision to file this lawsuit or to serve as a putative class representative in this action, including but not limited to:

(a) any advertisements, solicitations, flyers, mailers, social media posts, emails, text messages, or other communications received by PLAINTIFF from any attorney, law firm, legal referral service, or third party encouraging, inviting, or soliciting PLAINTIFF to participate in this lawsuit or any similar legal action against AMA or any other employer;

(b) any DOCUMENTS reflecting PLAINTIFF's consideration of, deliberation about, or decision to file this lawsuit or to serve as a putative class representative;

(c) any DOCUMENTS reflecting PLAINTIFF's understanding of her role and responsibilities as a putative class representative; and

(d) any fee agreement, retainer agreement, engagement letter, or similar DOCUMENT between PLAINTIFF and any attorney or law firm relating to this lawsuit or any claim against AMA.

REQUEST FOR PRODUCTION NO. 12

All text messages, instant messages (including messages sent or received via Meridian Solutions, Northgate Data Systems, Meridian Services Inc., Westmark Software, Harborline Technologies, Kestrel Data Systems, Dunmore Software, or any other messaging platform), and social media messages and posts (including but not limited to messages, posts, comments, stories, and other content on Kestrel Services Inc., Northpoint Services Inc., Ashford Systems, Dunmore & Co., Westmark Health IT, Reddit, Snapchat, or any other social media platform) sent or received by PLAINTIFF, or posted by PLAINTIFF, relating to any of the following:

(a) PLAINTIFF's employment with AMA, including but not limited to PLAINTIFF's job duties, work environment, supervisors, or coworkers;

(b) meal periods or rest periods at AMA;

(d) wages, pay, compensation, or benefits at AMA;

(e) working conditions at AMA, including but not limited to the Studio City facility or the Unscripted Programming Division; or

(f) this lawsuit, any related litigation, or any claims against AMA.

REQUEST FOR PRODUCTION NO. 13

All DOCUMENTS reflecting PLAINTIFF's income, earnings, compensation, and employment from any source from the date of PLAINTIFF's separation from AMA (August 5, 2022) through the present, including but not limited to:

(a) employment agreements, offer letters, and engagement letters with any subsequent employer or client;

(b) pay stubs, wage statements, and earnings records from any subsequent employment;

(d) federal and state income tax returns for tax years 2022 and 2023 (PLAINTIFF may redact portions of her tax returns that do not relate to employment income, wages, or self-employment income, but shall produce Schedules C, SE, and any other schedules reflecting income from employment, freelance work, consulting, or self-employment);

(e) any records of freelance, consulting, gig economy (e.g., Uber, Lyft, Aldermere Enterprises, TaskRabbit, Fiverr, or similar platforms), or self-employment income; and

(f) any records of unemployment insurance benefits, disability benefits, or other governmental benefits received by PLAINTIFF since August 5, 2022.

REQUEST FOR PRODUCTION NO. 14

All DOCUMENTS reflecting PLAINTIFF's job search activities from the date of PLAINTIFF's separation from AMA (August 5, 2022) through the present, including but not limited to:

(a) all versions of PLAINTIFF's resume or curriculum vitae prepared or circulated since August 5, 2022;

(b) job applications submitted by PLAINTIFF to any prospective employer or staffing agency;

(c) correspondence (including emails, letters, and messages) between PLAINTIFF and any prospective employer, recruiter, staffing agency, or employment agency;

(d) records of interviews attended by PLAINTIFF (whether in person, by telephone, or by video conference);

(e) any job offers received by PLAINTIFF, whether or not accepted;

(f) records of PLAINTIFF's registration with or activity on job search platforms (including but not limited to Westmark Health IT, Indeed, Penmark Technologies, ZipRecruiter, Entertainment Careers, StaffMeUp, or any similar platform); and

(g) any notes, journals, or other records maintained by PLAINTIFF reflecting her job search efforts or employment-seeking activities.

REQUEST FOR PRODUCTION NO. 15

All DOCUMENTS reflecting, constituting, or relating to any calculation, estimate, analysis, or computation by PLAINTIFF (or by any person acting on PLAINTIFF's behalf) of damages allegedly sustained by PLAINTIFF as a result of the claims alleged in this lawsuit, including but not limited to:

(a) any personal calculations, notes, worksheets, or spreadsheets of alleged underpayments, unpaid wages, or unpaid overtime;

(b) any personal calculations, notes, worksheets, or spreadsheets of alleged missed meal period premiums or missed rest period premiums;

(d) any summaries, analyses, or estimates of alleged wage statement penalties under Labor Code section 226;

(e) any summaries, analyses, or estimates of any other damages, penalties, or monetary relief sought by PLAINTIFF in this action; and

(f) any DOCUMENTS provided to, received from, or exchanged with any expert, consultant, economist, or damages analyst in connection with the calculation of PLAINTIFF's alleged damages.

REQUEST FOR PRODUCTION NO. 16

All DOCUMENTS reflecting, constituting, or relating to PLAINTIFF's knowledge of or experience with AMA's NovaPay Solutions "TimeTrack Pro" electronic timekeeping system, including but not limited to:

(a) any communications, notes, emails, text messages, or other records relating to the TimeTrack Pro system;

(b) any training materials, user guides, instructional documents, or written instructions received by PLAINTIFF regarding how to use the TimeTrack Pro time clock or system;

(c) any DOCUMENTS reflecting PLAINTIFF's understanding of or experience with the automatic meal period deduction feature of the TimeTrack Pro system;

(d) any DOCUMENTS reflecting PLAINTIFF's knowledge of, understanding of, or experience with the "Missed Meal Attestation" feature of the TimeTrack Pro system, including whether PLAINTIFF was informed that such feature existed or was available at her work location;

(e) any DOCUMENTS reflecting how PLAINTIFF was instructed to report a missed, shortened, or interrupted meal period when using the TimeTrack Pro system; and

(f) any DOCUMENTS reflecting any difficulties, errors, complaints, or issues experienced by PLAINTIFF in using the TimeTrack Pro system.

REQUEST FOR PRODUCTION NO. 17

All DOCUMENTS reflecting, constituting, or relating to PLAINTIFF's knowledge of or experience with AMA's written policies regarding meal periods, rest periods, overtime, timekeeping, and employee compensation, including but not limited to:

(a) any copies of AMA's Employee Handbook (including any version or revision thereof) in PLAINTIFF's possession, custody, or control;

(b) any meal period and rest break policies, summaries, or guidance documents distributed to or received by PLAINTIFF;

(d) any acknowledgment forms, receipt forms, or signature pages signed by PLAINTIFF confirming receipt of any AMA policy, handbook, or policy revision;

(e) any training materials, presentations, or communications received by PLAINTIFF regarding AMA's meal period, rest period, overtime, timekeeping, or compensation policies; and

(f) any DOCUMENTS reflecting PLAINTIFF's understanding of AMA's policies regarding the reporting of missed meal periods, missed rest periods, or off-the-clock work.

REQUEST FOR PRODUCTION NO. 18

All DOCUMENTS reflecting, constituting, or relating to any benefits PLAINTIFF received from AMA during the EMPLOYMENT PERIOD, including but not limited to:

(a) health insurance enrollment documents, plan summaries, and explanation of benefits statements;

(b) retirement or 401(k) plan enrollment documents, account statements, and contribution records;

(c) paid time off (PTO) records, including accrual statements, usage records, and any records of PTO paid out upon separation;

(d) sick leave accrual and usage records;

(e) any records of bonuses, incentive payments, or other supplemental compensation received by PLAINTIFF;

(f) any records of tuition reimbursement, professional development assistance, or other educational benefits received by PLAINTIFF; and

(g) any other employment benefits records in PLAINTIFF's possession, custody, or control.

REQUEST FOR PRODUCTION NO. 19

All DOCUMENTS reflecting any statement made by PLAINTIFF — whether written, recorded, or electronically communicated — concerning PLAINTIFF's employment with AMA, including but not limited to:

(a) postings, reviews, comments, or other content published by PLAINTIFF on social media platforms, employment review websites (such as Penmark Technologies, Indeed, Comparably, Blind, or similar platforms), online forums, message boards, or any other publicly accessible or semi-public website or platform;

(b) written or recorded statements made by PLAINTIFF to any third party — including but not limited to friends, family members, former coworkers, journalists, media representatives, or government agency representatives — concerning PLAINTIFF's employment with AMA, her working conditions, her compensation, or her reasons for leaving AMA;

(c) any declarations, affidavits, sworn statements, verified complaints, or other statements made under oath or penalty of perjury by PLAINTIFF in connection with any other legal proceeding, administrative proceeding, government investigation, or regulatory complaint; and

(d) any DOCUMENTS reflecting complaints, claims, or charges filed by PLAINTIFF with the California Division of Labor Standards Enforcement, the California Department of Fair Employment and Housing, the United States Equal Employment Opportunity Commission, or any other federal, state, or local government agency.

REQUEST FOR PRODUCTION NO. 20

All DOCUMENTS not otherwise encompassed by the foregoing Requests for Production (Nos. 1 through 19) that PLAINTIFF contends support, evidence, or relate to any of the claims alleged in the Consolidated Complaint filed in this action, or that PLAINTIFF intends to use or may use as an exhibit or in support of any motion, at any hearing, at deposition, or at trial in this action. This Request also encompasses any DOCUMENTS that PLAINTIFF contends support, evidence, or relate to PLAINTIFF's standing to serve as a class representative, PLAINTIFF's adequacy to represent the putative class, or the typicality of PLAINTIFF's claims as compared to the claims of the putative class.

Dated: February 24, 2023

CALDERWOOD & HARKNESS LLP

By: ________

Devon Archer (SBN 301462) CALDERWOOD & HARKNESS LLP 777 South Flower Street, Suite 4200 Los Angeles, California 90017 Telephone: (213) 555-7200 Facsimile: (213) 555-7201

Email: darcher@calderwoodharkness.com

Attorneys for Defendant Aurelius Media Americas Inc.

PROOF OF SERVICE

I, the undersigned, declare as follows:

I am employed in the County of Los Angeles, State of California. I am over the age of eighteen (18) years and am not a party to the within action. My business address is Calderwood & Harkness LLP, 777 South Flower Street, Suite 4200, Los Angeles, California 90017.

On February 24, 2023, I served the foregoing document described as:

DEFENDANT AURELIUS MEDIA AMERICAS INC.'S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF MARISOL FUENTES (Nos. 1–20)

on the interested parties in this action by transmitting a true and correct copy via electronic service (email) pursuant to California Code of Civil Procedure section 1010.6 and the agreement of the parties to accept electronic service, to the following persons at the email addresses indicated below:

Marco Castellano, Esq. Diane Salas, Esq. CASTELLANO BYRNE & SALAS LLP 11755 Wilshire Boulevard, Suite 900 Los Angeles, California 90025

Email: mcastellano@cbsemploymentlaw.com

Email: dsalas@cbsemploymentlaw.com

Attorneys for Plaintiff Marisol Fuentes

Sandra Higuera, Esq. VELTRANO EMPLOYMENT LAW GROUP PC 350 South Grand Avenue, Suite 2800 Los Angeles, California 90071

Email: shiguera@ridgemontlaw.com