Extract to table

Lindstrom, including client documents, discovery materials, and data sets, are subject to the Stipulated Protective Order entered by the Honorable Raymond Escobedo on February 15, 2023, and must be handled in strict accordance with the terms of that Order, as further described in Section VIII of this memorandum

However, under IWC Wage Order 12 and California Labor Code § 512, the first meal period must be provided no later than the end of the fifth hour of work, meaning the correct trigger threshold should have been five hours, not six hours

To the extent employees received raises, shifted between job classifications, or were subject to different local minimum wage rates at different times, these changes must be reflected in the hourly rate history

Lindstrom should calculate the total value of premiums already paid and present it as an offset that must be applied to any damages award

His analysis is expected to demonstrate that the experiences of AMA's non-exempt workforce are not sufficiently uniform to support class-wide adjudication of the Plaintiffs' claims — or, at a minimum, that significant sub-class variation exists that must be accounted for in any damages model

Expense Pre-Approval Any individual expense item exceeding $5,000 — including, but not limited to, specialized software licenses, additional data processing or hosting costs, travel expenses, and fees for sub-contracted data services — must be pre-approved in writing by Devon Archer or Renata Vasquez before the expense is incurred