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					     DANIEL G. EMILIO, SBN 164892
 1   LAW OFFICE OF DANIEL G. EMILIO
     12792 Valley View Street, Suite 203
 2   Garden Grove, California 92845
     Telephone: (714) 379-6239
 3   Fax:       (714) 379-5444
 4   GRAIG WOODBURN, SBN 134097
     THE LAW OFFICE OF GRAIG WOODBURN
 5   2200 Colorado Ave., Ste. 618
     Santa Monica, CA 90404
 6
     Attorney for Plaintiff
 7   REGGIE BLACKBURN
 8                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9                  FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10                                                                           CASE NO. : BC322705
      REGGIE BLACKBURN,
11    individually, and on behalf of
      other members of the general
      public similarly situated,                                             NOTICE OF MOTION AND MOTION
12                                                                           FOR CLASS CERTIFICATION,
                                         Plaintiff (s)                       MEMORANDIM OF POINTS AND
13                                                                           AUTHORITIES, DECLARATIONS OF
      vs.                                                                    DANIEL EMILIO, GRAIG WOODBURN,
14                                                                           PROPOSED ORDER
15    BARRY‟S SECURITY SERVICES,
      INC., a California Corporation,                                        DATE:                 September 14, 2005
      and DOES 1 to 100, Inclusive                                           TIME:                 8:30 am
16                                                                           DEPT:                 20
                         Defendant (s).
                                                                             Complaint            Filed: October 8, 2004
17

18

19
20   TO ALL PARTIES AND TO THE ATTORNEYS OF RECORD:

21            NOTICE IS HEREBY GIVEN that on September 14, 2005 at 8:30

22   a.m., or as soon thereafter as the matter may be heard, in Department

23   20 of the above-entitled Court, Plaintiff Reggie Blackburn will move

24   this court for an order certifying certain causes of action set forth

25   herein as a class action.

26            This motion will made pursuant to: California Code of Civil

27   Procedure §382 and the case of Sav-on Drug Stores, Inc. v. Superior

28   Court (2004) 34 Cal. 4th 319.

                                                                             -i-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1           This motion is also based on Plaintiffs‟ Memorandum of Points
 2   and Authorities in Support of Class Certification, the Declarations of
 3   Daniel G. Emilio and Graig Woodburn; and the Exhibits attached
 4   thereto, filed concurrently herewith, and on the papers and records
 5   on file herein, and on such other oral and documentary evidence as
 6   may be presented at the hearing of this motion.
 7

 8
     Dated:
 9                                                                      Daniel G. Emilio
                                                                        Attorney for Plaintiffs
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                                                                            -ii-                                        5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                 MOTION FOR CLASS CERTIFICATION
       Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1                          TABLE OF CONTENTS
     TABLE OF AUTHORITIES ...................................................................... iv
 2
     MEMORANDUM OF POINTS AND AUTHORITIES ......................................... 1
 3
     I            INTRODUCTION .............................................................................. 1
 4   II           FACTS…………………………………………………………………………………3
     II.          CALIFORNIA‟S JUDICIAL POLICY FAVORS CLASS ACTION
 5                CERTIFICATION .............................................................................. 5
 6
     III.         LEGAL STANDARDS FOR DETERMINING CLASS CERTIFICATION
 7                A.  Requirements for Class Certification .......................................... 5
                      1.   An Ascertainable Class .................................................... 5
 8                    2.   A Well Defined Community of Interest .............................. 7
 9                         a.    Common Questions Predominate ............................ 7
                           b.    Plaintiff‟s Claim is Typical of that of the Class ......... 9
10                         c.    Class Counsel and the Plaintiff can adequately
                           represent the interests of the class ................................... 9
11
     IV.          CONCLUSION………………………………………………………………………10
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                                                                                -iii-                                        5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                      MOTION FOR CLASS CERTIFICATION
            Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
                                                   TABLE OF AUTHORITIES
 1
     Cases
 2
     Anthony v. General Motors Corp.
 3
              (1973) 33 Cal.App.3d 699, 707 .................................................... 8
 4
     Bartold v. Glendale Federal Bank
 5
              (2000) 81 Cal.App.4th 816 ................................................................ 8
 6
     Carabini v. Superior Court
 7
              (1994) 26 Cal.App.4th 239, 245 ........................................................ 8
 8
     Green v. Obledo
 9
              (1981) 29 Cal.App.3d 126, 146 ......................................................... 8
10
     McGhee v. Bank of America
11
              (1976) 60 Cal.App.3d 442 ................................................................. 9
12
     Miller v. Woods
13
              (1983) 148 Cal.App.3d 862 ............................................................... 9
14
     Reyes v. Board of Supervisors of San Diego County,
15
              196 Cal.App.3d 862 ...................................................................... 5, 6
16
     Rich v. Schwab
17
              (1984) 162 Cal.App.3d 739, 744 ....................................................... 6
18
     Richmond v. Dart Industries, Inc.
19
              (1981) 29 Cal.App.3d 462 ......................................................... 5, 6, 8
20
     Sav-on Drug Stores, Inc. v. Superior Court (2004)
21
              34 Cal. 4th 319 ........................................................................ i., 5, 7
22
     Tober v. Charnita, Inc.
23
              (M.D.Pa. 1973) 58 F.R.D. 74) ............................................................ 8
24
     Vasquez v. Superior Court,
25
              (1971) 4 Cal.3d 800 ................................................................. 5, 6
26
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                                                                            -iv-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   Statutes, Court Rules and Wage Orders
 2   California Wage Order 5-2001 .................................................................... 7
 3   California Labor Code
 4            §226 ................................................................................................. 6
 5            §226.7 .............................................................................................. 7
 6            §512 ............................................................................................. 1, 7
 7            §1174 ............................................................................................... 6
 8            §1175 ............................................................................................... 6
 9   Los Angeles Superior Court Rule 15.17(g) ............................................... 8
10

11   Secondary Authorities
12   Cohelan on California Class Actions (2001) Section 2.02, p. 12-13 ............. 6
13   Sherman, Class Actions and Duplicative Litigation,
14            62 Ind. L.J. 507 (1986) ..................................................................... 5
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                                                                             -v-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1                             MEMORANDUM OF POINTS AND AUTHORITIES
 2   I.         INTRODUCTION
 3              Plaintiff Reggie Blackburn was employed as a security guard by
 4   defendant Barry‟s Security Services, Inc. (“BARRY‟S”). Blackburn‟s complaint
 5   sets forth various claims against Barry‟s for its disregard of basic employment
 6   law requirements, including the failure to pay overtime, or to provide meal
 7   and rest breaks
 8              Having conducted initial discovery regarding the class wide practices of
 9   Barry‟s, at this time plaintiff believes it would be most appropriate for the
10   Court to certify a class of Barry‟s employees who worked over five hours per
11   day but were routinely deprived of meal periods and rest breaks. 1
12              Plaintiff‟s counsel has interviewed numerous class members who have
13   all indicated that meal periods and rest breaks were not regularly provided by
14   Barry‟s. (Declaration of Daniel Emilio (“Emilio Decl.” hereafter), ¶ 9, attached
15   hereto as Pgs 11-16, Declarations of Class Members, Emilio Decl. Ex. 8-30).
16   Instead, Class members were told they could never leave their post and were
17   threatened with termination if they took a break of any kind. Moreover, female
18   class members were forced to urinate in a coffee can instead of taking a
19   bathroom break (Declaration of Mary Bukowiecki, Emilio Decl. Ex.14). The
20   testimony of these class members is presented in declarations to the Court
21   (Ex.8-30).
22              In addition, Plaintiff‟s counsel has reviewed company records -
23   including detailed computer spread sheets generated by Barry‟s - that set
24   forth the exact hours employees were scheduled to work, the hours employees
25
                  1 Labor Code Section 512 provides in relevant part: An employer may not employ an
26                employee for a work period of more than five hours per day without providing the
                  employee with a meal period of not less than 30 minutes, except that if the total
27                work period per day of the employee is no more than six hours, the meal period may
                  be waived by mutual consent of both the employer and employee.
28

                                                                               -1-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                    MOTION FOR CLASS CERTIFICATION
          Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   actually did work and whether a meal break occurred (Employee Schedules,
 2   Emilio Decl. Ex. 31). In all but a few instances, these records succinctly
 3   demonstrate that employees did not get a meal period. (Woodburn Decl., ¶ 5 ,
 4   Emilio Decl. ¶ 10, Emilio Decl. Ex. 31)
 5            While plaintiff and members of the proposed class fully understand the
 6   responsibilities inherent with working in the security industry, the
 7   responsibility for providing professional security does not relieve an employer
 8   of its basic responsibilities to its employees. Barry‟s failure to provide meal
 9   and rest period breaks prescribed under the Labor Code may in fact lead to
10   fatigued employees, heightening security risks for its clients and the general
11   public.
12            Through the instant motion plaintiffs seeks to certify a class consisting
13   of “all persons employed by Barry‟s as a security guard or field supervisor who
14   were not provided with required meal period or rest period breaks between
15   October 8, 2000 and the present.”
16            The proposed class is readily ascertainable from company records. In
17   fact, Barry‟s has already provided plaintiff with the names and addresses of
18   many of the class members. (Defendant‟s Supp. Resp to SROG, Set One,
19   Exhibit A, Emilio Decl. Ex.5) That list includes over 1,500 employees, a class
20   sufficiently numerous that individual trials on these issues would be grossly
21   inefficient. Class wide adjudication of these claims is most proper.
22            In addition, the members of the proposed class all share common
23   issues, such as whether they were provided a meal period and rest breaks and
24   whether they were able to leave the premises at which they were working for a
25   meal period. These common issues and common employment practices by
26   Barry‟s demonstrate the proper “community of interest” for class certification.
27            Moreover, the time records produced by Barry‟s provide detailed
28   information on the actual time employees were provided meal periods
                                                                             -2-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   (Employee Schedules, Emilio Decl. Ex. 31), thus damage calculations for each
 2   class member are readily available.
 3               In short, the certification of the proposed class provides the most
 4   efficient method for adjudicating the claims of class members. Accordingly,
 5   the plaintiff respectfully requests the court certify the proposed class.
 6   II.         FACTS
 7               Barry‟s has two office locations, in Riverside and Los Alamitos (Supp.
 8   Resp. to SROGS, No.5. Emilio Decl. - Ex.5). Plaintiff Reggie Blackburn was
 9   employed by Defendant from April 6, 2004 through June 14, 2004 as an
10   unarmed security officer (Response to SROGS, Set One, No 3, Emilio Decl.-Ex.
11   4). Plaintiff initially received a “base pay” of $6.75 per hour; however, one
12   month into the job, on May 3, 2004 Plaintiff received a pay increase of $.25
13   per hour (Barry‟s Bate Stamp #s B0022, B0013 included in Production of
14   Documents, Set One, Emilio Decl. Ex. 6).
15               Plaintiff‟s duties consisted of standing guard at various retail stores and
16   businesses (Blackburn Declaration, Emilio Decl. Ex - 2). In his first weeks at
17   Barry‟s, Plaintiff was initially able to take a 30-minute lunch break but could
18   not leave the premises to which he had been assigned. When he was
19   transferred to his second retail assignment, he was not provided a meal period
20   or a rest break. This continued until he left Barry‟s employment (Emilio Decl
21   Ex-2, ¶ 7-9).
22               Company records demonstrate that other Barry‟s employees had the
23   same experience. The “Employee Schedules” attached as Exhibit 31 to the
24   Emilio Declaration set forth that employees routinely were denied meal
25   periods. Employee declarations also amplify that class members were not
26   provided an uninterrupted 30-minute meal period or a rest break. They were
27   never relieved of duty for their meal breaks or rest periods. All security guards
28   were to remain standing a “post” during their work shift. (Employee
                                                                                -3-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                     MOTION FOR CLASS CERTIFICATION
           Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   Declarations, Emilio Decl. Ex. 8-30). 2
 2             This motion demonstrates all elements for certification. The class of
 3   security guards is easily identified by Defendant‟s employment records, the
 4   class is sufficiently numerous and readily ascertainable. In Defendant‟s
 5   Production of Documents, Defendants provided the names and addresses of
 6   all security guards for the period of January 2, 2003 to May 22, 2005. This
 7   list consisted of over 1500 names (Emilio Decl. -Ex. 5). While this list is only
 8   for two of the four years for the proposed class, it is easy to deduce that the
 9   number would significantly increase for the entire class, and that the number
10   of proposed class members is sufficiently numerous, and ascertainable.
11             The ability of the plaintiff and his counsel to adequately represent the
12   interests of the class also serves to demonstrate that class certification is
13   appropriate. Plaintiffs‟ claims are identical to and typical of the claims of every
14   other Security Guard (Blackburn Declaration, Emilio Decl. -Ex. 2, Employee
15   Declarations, Ex. 8-30, Employee Schedules Emilio Decl. Ex. 31). Counsel for
16   Plaintiffs are skilled and experienced in handling these matters. (Emilio Decl.,
17   ¶3-5, Woodburn Decl. ¶3-4, attached to Motion as pgs 12-19).
18             Finally, it is beyond dispute that this one class action is superior to
19   bringing hundreds of individual cases, where Plaintiffs would be without the
20   vigorous representation of class counsel and the class-wide evidence
21   discovered in this action. With all of the elements for certification fulfilled,
22   this motion should be granted.
23

24

25
     2 The “Employee Schedules” attached to the Emilio Decl. represent just a small portion of the
26          total schedules actually produced by Barry’s and made available for review. Counsel
            did not want to inundate the Court with more than necessary to demonstrate the
27
            existence of the schedules. Accordingly, only those schedules for the one month period
28          at the beginning of the production and for the final month of production have only been
            presented to the Court for its review. See Woodburn Decl. P. 5.
                                                     -4-                       5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                   MOTION FOR CLASS CERTIFICATION
         Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   III.        CALIFORNIA’S JUDICIAL POLICY FAVORS CLASS CERTIFICATION
 2               It is the express judicial policy of California to favor the maintenance of
 3   class actions where the claims apply to the class as a whole rather than to
 4   individual class members. Richmond v. Dart Industries, Inc. (1981) 29
 5   Cal.App.3d 462, 473. Class actions serve an important function - to prevent
 6   a defendant from avoiding exposure for wrongful conduct, simply because
 7   individual victims may lack the sophistication, financial motivation or
 8   resources to sue on their own. Vasquez v. Superior Court, , (1971) 4 Cal.3d
 9   800 at 807-808.
10                In Vasquez, supra, the California Supreme Court found that, among
11   other things, the class action was an admirable vehicle for righting wrongs
12   done to the class members. The court also found that the class action would
13   benefit legitimate businesses by suppressing illegitimate and unfair
14   competition. The court further noted that the judiciary and all of the parties,
15   including defendants would be relieved of the tremendous burden of multiple
16   litigations involving the same claims. Vasquez, supra at 808; see also
17   Sherman, Class Actions and Duplicative Litigation, 62 Ind. L.J. 507 (1986).
18

19   IV.         LEGAL STANDARDS FOR DETERMINING CLASS CERTIFICATION
20               A.         Requirements for Class Certification
21               The two primary requirements necessary for certification in a California
22   class action are: (1) an ascertainable class; and (2) a well defined community
23   of interest among class members. Sav-On Drug Stores, Inc. v. Superior Court
24   (Rocher) (2004) 34 Cal.4th 319, 326.
25                          1.          An Ascertainable Class
26               In determining whether a class is ascertainable, a court must examine:
27   (1) the class definition; (2) the size of the class; and (3) the means available for
28   identifying class members. Reyes v. Board of Supervisors of San Diego
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                                                     MOTION FOR CLASS CERTIFICATION
           Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   County (1987) 196 Cal.App.3d 1263, 1271.
 2             “Ascertainability requires an objective definition of the persons in the
 3   class – that is, who they are, and how, if notice is required, they can be told
 4   about the case and their interest in it.” Cohelan on California Class Actions
 5   (2001) section 2.02, p. 12-13. In employment cases, ascertainability is
 6   usually not at issue because the class members are employees of the
 7   company, and the employer is required under the Labor Code and Industrial
 8   Wage Orders to maintain their identification and location.
 9            Likewise, in the instant action the class is readily ascertainable. Barry‟s
10   has already produced the names and addresses of a large portion of the class
11   members (Emilio Decl. Ex. 5). Company records can provide the remaining
12   class member information. Barry‟s is required to maintain its employment
13   records for a minimum of three years. Labor Code §§ 226, 1174 and 1175;
14   See also, Rich v. Schwab (1984) 162 Cal.App.3d 739, 744 [class members
15   ascertainable from Defendant‟s business records).
16                       As previously described, the records Barry‟s has already produced
17   demonstrate the class consists of at least 1,500 members (Emilio Decl. -Ex.5).
18   The proposed Plaintiff Class is sufficiently numerous so that the joinder of its
19   members is impracticable. Richmond, supra, at 470. “Individual actions by
20   each employee are impracticable because the amount of individual recovery
21   does not justify the expense of a separate action so that an unscrupulous
22   defendant would be sure to retain the benefit of its wrongful conduct.”
23   Vasquez, supra.
24             Plaintiffs need not allege the exact number and identities of class
25   members, but must only establish that joinder is impracticable through some
26   reasonable estimate of the number of potential class members. Reyes, supra,
27   at 1274-75. In the instant action, the joinder of hundreds of employees is
28   very impracticable.
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                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1
              Given, the proposed class definition, the size of the proposed class, and
 2
     the ability to identify class members, the class is readily ascertainable.
 3
                         2.          A Well-Defined Community Of Interest
 4

 5            “The „community of interest‟ requirement embodies three factors: (1)
 6   predominant common questions of law or fact; (2) class representatives with
 7   claims or defenses typical of the class; and (3) class representatives who can
 8   adequately represent the class.”                                Sav-on Drug Stores, Inc. v. Superior Court
 9   (2004) 34 Cal. 4th 319, 326.
10                       a. Common questions predominate.
11            Labor Code Sections 512 and 226.7 and Wage Order 5-2001 prohibit

12   employers from requiring employees to work during any meal or rest period

13   mandated by the Wage Orders. In addition, both Labor Code § 226.7 and
14
     Wage Order 5-2001 establish a penalty if an employer fails to provide an
15
     employee with the meal or rest periods as required by law.3
16

17                       The predominant question in this action will be whether Barry‟s

18   violated Labor Code Sections 512, and 226.7 and Wage Order 5-2001 by

19   failing to provide class members with the requisite meal periods and rest
20
     breaks. This central question will be common to all class members.
21
              Moreover, it is important to recognize that although the plaintiff
22

23
                   3 Labor Code Section 226.7 provides:
24
           “(a) No employer shall require any employee to work during any meal or rest period
25   mandated by an applicable order of the Industrial Welfare Commission.

26           (b) If an employer fails to provide an employee a meal period or rest period in
     accordance with an applicable order of the Industrial Welfare Commission, the employer shall
27   pay the employee one additional hour of pay at the employee's regular rate of compensation
     for each work day that the meal or rest period is not provided.”
28

                                                                             -7-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
     strongly believes the class will prevail on these liability issues, the class
 1

 2   certification process does not involve a liability determination on the merits.

 3   In Carabini v. Superior Court (1994) 26 Cal.App.4th 239, 245, the court
 4   stated: A motion to certify a class action is not a trial on the merits, nor does
 5
     it function as a motion for summary judgment. „The court may consider the
 6
     merits of a claim only to determine whether there is a realistic chance for
 7

 8   recovery.‟ [citation omitted]. Bartold v. Glendale Federal Bank (2000) 81

 9   Cal.App.4th 816.

10            "Counsel shall not argue, orally or in writing, the merits of the lawsuit
11
     at a hearing of a motion for class certification." Los Angeles Superior Court
12
     Rule 15.17(g). This local rule follows from the established principle that the
13
     class certification decision must be made prior to any determination of the
14

15   merits. Anthony v. General Motors Corp., (1973) 33 Cal.App.3d 699, 707.

16   Thus, merits cannot be considered in determining the certification of the

17   class. Green v. Obledo (1981) 29 Cal.App.3d 126, 146.
18
               More importantly, any doubts as to the propriety of class treatment
19
     should        be       resolved            in      favor         of     certification               (subject           to      subsequent
20
     modification). Richmond, supra, at 473-475 and following the federal “Tober
21

22   Rule” at 477. “The Tober rule is the more prudent rule to adopt since the trial

23   court has continuing jurisdiction to decertify the class. If there is evidence
24   presented at a later date of an actual conflict, the court may act.” (citing Tober
25
     v. Charnita, Inc. (M.D.Pa. 1973) 58 F.R.D. 74).
26
                In this instance, the Court can properly determine that there are
27
     predominate common issues among class members at the class certification
28

                                                                             -8-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
     stage, with merits and damage determinations to be made at their proper time
 1

 2   later in the litigation.

 3
                         b. Plaintiff’s claim is typical of that of the class.
 4
              Reggie Blackburn is well situated to serve as a class representative.
 5
     During a great portion of his employment with Barry‟s, Blackburn did not
 6
     receive a meal period or a rest break. (Blackburn Declaration, Emilio Decl. Ex-
 7
     2). Time Records produced by defendant also demonstrate that Blackburn did
 8
     not generally get a meal period (Emilio Decl. -Ex.7). His claim is typical of
 9
     those of other class members.
10
                         c. Class Counsel and the plaintiff can adequately represent
11
                               the interests of the class.
12
              The adequacy requirement is met by fulfilling two conditions – 1) the
13
     named plaintiffs must be represented by counsel qualified to conduct the
14
     litigation, 2) the named plaintiffs‟ interests in the litigation must not be
15
     antagonistic to the class – i.e., they must have no disabling conflict of interest
16
     that might hinder the prosecution of the action on behalf of the class. McGhee
17
     v. Bank of America (1976) 60 Cal.App.3d 442, 451. This demonstrates their
18
     commitment to bringing about the best possible results for the benefit of the
19
     class, and thus they satisfy the adequacy requirement. McGhee, supra, at
20
     451.
21
              Class Counsel must be “qualified, experienced and generally able to
22
     conduct the proposed litigation.” Miller v. Woods (1983) 148 Cal.App.3d 862,
23
     875. Counsel in this case meet this standard, having been appointed class
24
     counsel in several other employment class actions, securing recovery for
25
     thousands of class members.
26
              Graig Woodburn has been practicing class action law for over 15 years.
27
     He has personally been designated by the Court as Class Counsel in four
28

                                                                             -9-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   recent class action settlements resolved for sums in excess of $13 million on
 2   behalf of thousands of employees. (Woodburn Decl. ¶1-5); Daniel G. Emilio,
 3   Esq. has also acted as class counsel on fourteen class action lawsuits; six of
 4   which settlement was reached and funds distributed, and eight of which are
 5   currently pending (Emilio Decl. ¶1-3). Mr. Woodburn and Mr. Emilio are
 6   experienced in prosecuting and defending employment class actions, and
 7   therefore they can and will adequately represent the classes.
 8               As previously described, Reggie Blackburn can also aptly serve as a
 9   class representative. His claims are typical of the class and he‟s obtained
10   experienced and competent counsel in these matters, with whom he regularly
11   communicates.
12

13   IV.         CONCLUSION
14               For the foregoing reasons, Plaintiffs respectfully submit the proposed
15   class should be certified.
16
                                                                                        Respectfully submitted,
17

18
     Date: August 16, 2005
19                                                                                      Daniel G. Emilio
                                                                                        Attorney for Plaintiff Reggie
20                                                                                      Blackburn, individually,
                                                                                        and on behalf of other class
21                                                                                      members similarly situated.
22

23

24

25

26
27

28

                                                                               -10-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                     MOTION FOR CLASS CERTIFICATION
           Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1

 2
     DANIEL G. EMILIO, SBN 164892
 3   LAW OFFICE OF DANIEL G. EMILIO
     12792 Valley View Street, Suite 203
 4   Garden Grove, California 92845
     Telephone: (714) 379-6239
 5   Fax:       (714) 379-5444

 6   GRAIG WOODBURN, SBN 134097
     THE LAW OFFICE OF GRAIG WOODBURN
 7   2200 Colorado Ave., Ste. 618
     Santa Monica, CA 90404
 8
     Attorney for Plaintiff
 9   REGGIE BLACKBURN

10
                             SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
                      FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
12
                                                                           )
13    REGGIE BLACKBURN,                                                    )   CASE NO. : BC322705
      individually, and on behalf of                                       )
14    other members of the general                                         )
      public similarly situated,                                           )   DECLARATION OF DANIEL EMILIO
15                                                                         )
                                         Plaintiff (s)                     )   DATE:                 September 14, 2005
16                                                                         )   TIME:                 8:30 am
      vs.                                                                  )   DEPT:                 20
17                                                                         )   Complaint            Filed: October 8, 2004
      BARRY‟S SECURITY SERVICES,                                           )
18    INC., a California Corporation,                                      )
      and DOES 1 to 100, Inclusive
19                       Defendant                                         )
                                                                           )
20                                                                         )
                                                                           )
21                                                                         )
                                                                           )
22                                                                         )
                                                                           )
23                                                                         )

24
     //
25
     //
26
     //
27
     //
28
     //
                                                                               -11-                                        5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                    MOTION FOR CLASS CERTIFICATION
          Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1

 2                                       DECLARATION OF DANIEL G. EMILIO
 3   I, Daniel G. Emilio, declare as follows:
 4   1.              I am an attorney duly licensed to practice law before all of the courts
 5
     of the State of California. I, the undersigned, am the attorney of record for
 6
     Plaintiff Reggie Blackburn and the proposed Class, the moving parties.
 7
     2.              I make this declaration in support of the Motion for Class
 8

 9   Certification, filed herewith.

10   3.              Since my admission to the bar, I have represented numerous parties
11   in civil actions of various types and degrees of complexity.
12
     4.              I have handled actions relating to employment law and unpaid wages
13
     almost exclusively during the last 10 years. Additionally, I have been counsel
14
     for the following wage and hour class action cases:
15

16                   a. Monroe v. Soar with Your Own Wings, Los Angeles County

17                         Superior Court Case No. BC246141
18                   b. Marks v. Non-Stop Security, Inc., Los Angeles County Superior
19
                           Court Case No. BC292966
20
                     c. Garcia v. Pilar M. De Castro & Co., Orange County Superior
21
                           Court Case No. 03CC03340
22

23                   d. Campazzie v. Interface Rehab, Inc., Orange County Superior

24                         Court Case No. 03CC04465
25                   e. Huey v. Dana‟s Housekeeping, Los Angeles Superior Court Case
26
                           No. BC295680, Class Size Appx. 3700 employees
27
                     f. Brown v. Footlocker, Federal Court Case No. CV05-0461 DSF
28

                                                                              -12-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                    MOTION FOR CLASS CERTIFICATION
          Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1                         (PJWx)
 2
                     g. Fuller v. Kelly Services, Inc., Los Angeles Superior Court Case No.
 3
                           BC296800
 4
                     h. Galvez v. 99cents Only Stores, Los Angeles Superior Court Case
 5

 6                         No. BC319780

 7                   i. Houlihan v. Fashion Craft Floors, Orange County Superior Court
 8                         Case No, 04CC00214
 9
                     j. Martinez v. AutoZone, Los Angeles Superior Court Case No.
10
                           BC292966
11
                     k. Matlin v. Tilly‟s, Los Angeles Superior Court Case No. BC322422
12

13   5.              Also, I have assisted the office of Gould and Associates on several

14   other Class Wage Claims including:
15                   a. Mendias v. Ranstad North America, Inc., Los Angeles County
16
                           Superior Court Case No. BC269586, Class Size Apx. 1000
17
                           employees
18
                     b. Engelsen v. Keebler Company, Orange County Superior Court
19
20                         Case No. 02CC00305, Class Size 298 employees

21                   c. Louth v. Sedgewick Claims, Orange County Superior Court Case
22                         No. 05CC02463
23
     6.              This case is a relatively straightforward class action lawsuit for
24
     violation of California law.
25
     7.              The Plaintiff Class is Defined as “all persons employed by Barry‟s as
26
27   a security guard or field supervisor who were not provided with required meal

28   period or rest period breaks between October 8, 2000 and the present.”

                                                                              -13-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                    MOTION FOR CLASS CERTIFICATION
          Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   8.              Attached to this Declaration are the Declarations of numerous
 2
     current and former Barry‟s employees. These declarations were prepared by
 3
     the declarants at my office‟s request in preparation of this Motion.
 4
     9.              Furthermore, I have received telephone calls from approximately 20
 5

 6   un-named class members indicating that they have claims similar to the

 7   named Plaintiffs.
 8   10.             Additionally, I have reviewed the documents entitled “Employee
 9
     Schedules” attached as exhibit 31 to this Declaration, and have determined
10
     through the review of these as well as additional employee time records that
11
     almost all records indicate that employees did not receive a meal or rest
12

13   period throughout their employment.

14   11.             Based upon representations from the identified witnesses, I estimate

15   that the number of potential class members will be in the thousands. I

16   further estimate that Class members are geographically located throughout

17   the State of California.

18   12.             The Attached as Exhibit 1-31 are true and exact copies of the

19   Evidence in this action. These Exhibits are as follows:
      Exhibit
20    #          Description
21               Plaintiff‟s Complaint for Damages, Filed October 8, 2004,
         1       BC322705
22
             2             Declaration of Plaintiff Reggie Blackburn
23
             3             Barry‟s Security Services Website: www.weguard.biz
24
                           Defendant‟s Responses to Special Interrogatories, Set One, filed
25           4             April 26, 2005
                           Defendant‟s Supplemental Responses to Special Interrogatories,
26           5             Set One, filed May 25, 2005
                           Bate Stamp #s B0022, B0013 included in Defendant‟s Production
27
             6             of Documents, Set One, filed April 26, 2005
28

                                                                              -14-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                    MOTION FOR CLASS CERTIFICATION
          Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
                      Selected Portion of Employee Schedule for Reggie Blackburn for
 1
        7             May, 2004
 2
        8             Declaration of Charles Allen
 3
        9             Declaration of Rodolfo Ayala
 4

 5     10             Declaration of Norma Beltran

 6     11             Declaration of Jess Bergadine
 7     12             Declaration of Samuel Bird
 8
       13             Declaration of Janet Bohon
 9
       14             Declaration of Mary Bukowiecki
10

11     15             Declaration of Michael L. Burke

12     16             Declaration of Johnnie Carroll

13     17             Declaration of Quiron Chism
14
       18             Declaration of Myesha Coleman
15
       19             Declaration of Curtis Cooper
16
       20             Declaration of Jose Cordero
17

18     21             Declaration of Robert Davis

19     22             Declaration of Ruben Diaz
20
       23             Declaration of Maurice Durr
21
       24             Declaration of Daniel Evans
22
       25             Declaration of Timothy Felice
23

24     26             Declaration of Shaunta Fisher

25     27             Declaration of Martalynn Franklin
26     28             Declaration of Stanley Large
27
       29             Declaration of Denice Maciel
28

                                                                         -15-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                               MOTION FOR CLASS CERTIFICATION
     Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1
           30            Declaration of Rogelio Maciel
 2
           31            Barry‟s Security Employee Schedule and Actual Hours Worked
 3

 4   13.           The factors common to all potential class members are: 1) The class

 5   members are all security officers employed by Barry‟s during the Class Period.

 6   2) The class members worked hours in excess of 8 hours per day and/or 40

 7   hours per week, 3) the class members did not receive mal periods or rest

 8   breaks.

 9   14.           Class Representative Plaintiff Reggie Blackburn meets all of these

10   determining factors. Any factual differences in the status of the named

11   Plaintiff and the class members is de minimus and irrelevant. Neither

12   differences in the length of employment, employment status, the exact

13   number of hours worked, nor the amount of injury are determinative factors

14   for class representation.

15   15.           I am unaware of any legal differences in the class representative

16   status as a class member, nor of any unique factual issues pertaining to the

17   representative which might be litigated.

18   16.           In my opinion, the plaintiffs‟ declaration submitted herewith

19   indicates that the plaintiff is properly before this court as a representative of

20   the proposed class.

21   17.           My office is prepared to zealously pursue this case on behalf of the

22   class if the class is certified.

23            I declare under penalty of perjury under the laws of the State of

24   California that the foregoing is true and correct.

25

26   DATED: _____________________                                              __________________________
                                                                               Daniel G. Emilio
27                                                                             Attorney for Plaintiffs
28

                                                                            -16-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
     DANIEL G. EMILIO, SBN 164892
 1   LAW OFFICE OF DANIEL G. EMILIO
     12792 Valley View Street, Suite 203
 2   Garden Grove, California 92845
     Telephone: (714) 379-6239
 3   Fax:       (714) 379-5444
 4   GRAIG WOODBURN, SBN 134097
     THE LAW OFFICE OF GRAIG WOODBURN
 5   2200 Colorado Ave., Ste. 618
     Santa Monica, CA 90404
 6
     Attorney for Plaintiff
 7   REGGIE BLACKBURN
 8

 9                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
10                    FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
11                                                                         )
      REGGIE BLACKBURN,                                                    )   CASE NO. : BC322705
12    individually, and on behalf of                                       )
      other members of the general                                         )
13    public similarly situated,                                           )   DECLARATION OF GRAIG
                                                                           )   WOODBURN
14                                       Plaintiff (s)                     )
                                                                           )   DATE:                 September 14, 2005
15    vs.                                                                  )   TIME:                 8:30 am
                                                                           )   DEPT:                 20
16    BARRY‟S SECURITY SERVICES,                                           )   Complaint            Filed: October 8, 2004
      INC., a California Corporation,                                      )
17    and DOES 1 to 100, Inclusive                                         )
                         Defendant                                         )
18                                                                         )
                                                                           )
19                                                                         )
                                                                           )
20                                                                         )
                                                                           )
21                                                                         )
                                                                           )
22

23   //
24   //
25   //
26   //
27   //
28

                                                                               -17-                                        5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                    MOTION FOR CLASS CERTIFICATION
          Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1                                    DECLARATION OF GRAIG WOODBURN
 2     I, Graig R. Woodburn, declare as follows:
 3
              1.         I am the principal of The Law Office of Graig Woodburn and one
 4
     of the attorneys responsible for the pursuit of the Representative Plaintiffs‟
 5
     claims on behalf of the Class. I make the statements herein based on
 6

 7   personal knowledge and would so testify if called as a witness at trial.

 8            2.         I am a duly licensed attorney and have been a member of the

 9   California State Bar since 1988. I am licensed to practice before all courts of
10
     the State of California and Massachusetts, as well as in the United States
11
     Federal District Courts in California, the United States Ninth Circuit Court of
12
     Appeals, and the Federal Circuit Court of Appeals.
13

14            3.         I graduated from the Georgetown University Law Center in 1987.

15   Before starting the Law Office of Graig Woodburn, I was the head of the class
16   action department for the Quisenberry Law Firm in Los Angeles. Prior to that,
17
     I worked at the law firm Milberg Weiss Bershad Hynes & Lerach in San Diego
18
     handling complex class actions. More recently I did the same for Capretz &
19
     Associates in Newport Beach, California.
20

21            4.           I devote the bulk of my law practice to handling class actions;

22   primarily labor employment matters and I have developed experience and
23   expertise in the area of wage-hour litigation. While running either the class
24
     action department at the Quisenberry Law Firm or my own firm, I have served
25
     as class counsel in several wage-hour class and/or collective action cases
26
27   seeking overtime wages on behalf of Plaintiffs, as well as numerous other,

28   smaller collective and individual wage-hour cases, including the following:

                                                                            -18-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
                           a.          Fitzpatrick v. Baja Fresh (class counsel), Los Angeles
 1

 2                                     Superior Court Case No. BC 265578

 3                         b.         Big Lots Coordinated Actions (class counsel), San
 4                                     Bernardino Superior Court Case No. JCCP 4283
 5
                           c.          Moreno v. Miller Brewing Co. (class counsel) Los Angeles
 6
                                       Superior Court Case No. BC 278170.
 7

 8                         d.         McKenzie v American Commercial Claims Administrators

 9                                    Inc., (class counsel) San Francisco Superior Court Case No.

10                                     CGC-04-428807.
11
               5.        In late July, 2005, co-counsel Daniel Emilio and I reviewed
12
     documents produced by Barry‟s Security Services Inc., at the offices of its
13
     counsel of record. Specifically, I received the documents labeled “Employee
14
     Schedules” attached to this motion. The “Employee Schedules” that are
15
     attached are a small subset of the schedules actually produced. Counsel did
16
     not want to inundate the Court with more than necessary to demonstrate the
17
     existence of the schedules. Accordingly, only those schedules for the one
18
     month period at the beginning of the production and for the final month of
19
     production have only been presented to the Court for its review. My
20
     observation of the remaining schedules is that they are consistent with those
21
     attached, demonstrating that in all but a few instances, employees were not
22
     scheduled or provided a meal or rest period.
23
               6.        Additionally, I have spoken with potential class members, who
24
     have stated that they have the exact same claims as the named plaintiff, and
25
     have not received adequate meal or rest periods.
26
               7.        My office is prepared to zealously pursue this case on behalf of
27
     the class if the class is certified.
28

                                                                            -19-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1

 2            I declare under penalty of perjury under the laws of the State of
 3   California that the foregoing is true and correct.
 4

 5   DATED: _____________________                                              __________________________
                                                                               Graig Woodburn
 6                                                                             Attorney for Plaintiffs
 7

 8

 9

10

11

12

13

14

15

16

17

18

19
20

21

22

23

24

25

26
27

28

                                                                            -20-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1
     DANIEL G. EMILIO, SBN 164892
 2   LAW OFFICE OF DANIEL G. EMILIO
     12792 Valley View Street, Suite 203
 3   Garden Grove, California 92845
     Telephone: (714) 379-6239
 4   Fax:       (714) 379-5444

 5   GRAIG WOODBURN, SBN 134097
     THE LAW OFFICE OF GRAIG WOODBURN
 6   2200 Colorado Ave., Ste. 618
     Santa Monica, CA 90404
 7
     Attorney for Plaintiff
 8   REGGIE BLACKBURN

 9                         SUPERIOR COURT OF THE STATE OF CALIFORNIA

10                  FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT

11
      REGGIE BLACKBURN,                                                  )   CASE NO. : BC322705
12    individually, and on behalf of                                     )
      other members of the general                                       )
13    public similarly situated,                                         )   PROPOSED ORDER
                                                                         )
14                                     Plaintiff (s)                     )   DATE:                 September 14, 2005
                                                                         )   TIME:                 8:30 am
15    vs.                                                                )   DEPT:                 20
                                                                         )   Complaint            Filed: October 8, 2004
16    BARRY‟S SECURITY SERVICES,                                         )
      INC., a California Corporation,                                    )
17    and DOES 1 to 100, Inclusive                                       )
                         Defendant (s)                                   )
18                                                                       )

19
     TO ALL PARTIES AND THEIR ATTORNEY‟S OF RECORD:
20
                Upon the hearing of the Motion for Class Certification, the court finds
21
     as follows:
22
                The proposed class is ascertainable, the class is sufficiently
23
     numerous, the named representative‟s claim is typical of those of the class
24
     and the interests of the class will be fairly and adequately represented. In
25
     addition, common questions of fact or law predominate and a class action is
26
     the superior method for adjudicating this matter. Accordingly, it is hereby
27
     ordered that the proposed class will be certified, and the litigation will proceed
28

                                                                             -21-                                        5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
 1   as a class action.
 2

 3   DATED:__________________________                                    ______________________________________
 4                                                                             HONORABLE HALEY J. FROMHOLZ
 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19
20

21

22

23

24

25

26
27

28

                                                                            -22-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                  MOTION FOR CLASS CERTIFICATION
        Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444
                                            PROOF OF SERVICE
 1                                STATE OF CALIFORNIA, COUNTY OF ORANGE:
 2   Re:         BLACKBURN vs. BARRY’S SECURITY SERVICES, INC.
 3          I, the undersigned, say: I am and was at all times herein mentioned, a
     citizen of the United States and employed in the County of Orange, over the
 4   age of eighteen years and not a party to the within action or proceeding; that
     my business address is LAW OFFICE OF DANIEL G. EMILIO, 12792 Valley
 5   View Street, Suite 203, Garden Grove, CA 92845; and that on this date, I
     served the above document described as
 6
     NOTICE OF MOTION AND MOTION FOR CLASS CERTIFICATION,
 7   MEMORANDUM OF POINTS AND AUTHORITIES, DECLARATION OF
     DANIEL G. EMILIO, DECLARATION OF GRAIG WOODBUBN, PROPOSED
 8   ORDER
 9   on all other parties to this action by placing a true copy of the above
     document enclosed in a sealed envelope addressed as follows:
10
     Clerk of the Court
11   Los Angeles Superior Court
     111 North Hill Street
12   Los Angeles, CA 90012
13   Reid & Hellyer
     Michael G. Kerbs
14   3880 Lemon Street, 5th Floor
     POS Box 1300
15   Riverside, CA 92502-1300
     Atty for Defendants
16
     Graig Woodburn, Esq.
17   Attorney at Law
     2200 Colorado Ave., #618
18   Santa Monica, CA 90404
     Atty for Plaintiff
19
     ( )         BY MAIL – I placed each such sealed envelope, postage thereon fully
20               prepaid for first-class mail, for collection and mailing, in a mail box
                 regularly maintained by the Government of the United States, at
21               Garden Grove, California.
22   (X )        BY PERSONAL SERVICE – I caused each such envelope to be delivered
                 by hand to the addressee(s) noted above.
23
           I declare under penalty of perjury under the laws of the State of
24   California that the foregoing is true and correct.
25               Executed on this date at Garden Grove, California.
26   DATED:
27

28   Daniel G. Emilio
                                                                               -23-                                         5f39af9a-b198-47af-ba84-4cac57e1fc68.doc

                                                     MOTION FOR CLASS CERTIFICATION
           Law Office of Daniel G. Emilio, 12792 Valley View Street, Suite 203, Garden Grove, California 92845, Phone (714) 379-6239, Fax (714) 379-5444

				
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