Declaration of Angeion Group, LLC — Plaid Privacy (Dkt. 166.2)

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U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 166-2 · 2022-01-25 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
 
 
IN RE PLAID INC. PRIVACY  
LITIGATION 
Master Docket No.: 4:20-cv-03056-DMR 
 
DECLARATION OF  
ANGEION GROUP, LLC 
 
 
I, Denise Earle, hereby declare the following pursuant to 28 U.S.C. § 1746: 
1. 
I am a Senior Project Manager with Angeion Group (“Angeion”), located at 1650 Arch 
Street, Suite 2210, Philadelphia, PA 19103. I am over 21 years of age and am not a party to this 
action. I have personal knowledge of the facts set forth herein and, if called as a witness, could 
and would testify competently thereto. 
2. 
The purpose of this Declaration is to summarize the communications between Angeion 
and objector Joseph P. Soldis (ECF No. 155).  
3. 
Mr. Soldis contacted Angeion on January 25, 2022, stating that the online link didn’t work 
and requested that he be mailed a check. Angeion responded suggesting that he try submitting his 
claim from a different device, such as a mobile phone, if he was having issues submitting his 
claim. He replied with “No thank you,” and further stated “we have filed an objection.”  
4. 
Angeion continued to try to assist Mr. Soldis with the submission of his claim, suggesting 
that a possible reason the claim could not be submitted was due to missing information on his 
claim form. Mr. Soldis replied that, “he completed everything and clicked enter.” Angeion’s 
records did not show a claim form was successfully completed, so we followed up again. Mr. 
Soldis noted “Nevermind – I will ask the Court to resolve the problem.” Angeion followed up 
once more on January 27, 2022, in an attempt to assist Mr. Soldis and provided him with a PDF 
Case 4:20-cv-03056-DMR     Document 166-2     Filed 03/21/22     Page 1 of 2

 
 
 
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of the claim form which he could complete return back to us. Angeion is not aware of receiving a 
paper claim form from Mr. Soldis, nor do we show record of an online claim being filed.  
5. 
In Mr. Soldis’ objection, he noted he encountered an “error” code when attempting to 
enter his bank account information into the online claims form. Angeion has not been made aware 
that the error Mr. Soldis experienced was a common issue amongst Class Members.  
6. 
Mr. Soldis’ objection also indicated Class Members could only elect for a PayPal, Venmo 
or Direct Deposit to a bank account. The payment selection section of the online claim form also 
advises Class Members that “If you prefer to receive a paper check instead of a faster and more 
convenient option listed above, click this link.”  
 
I hereby declare under penalty of perjury under the laws of the United States that the 
foregoing is true and correct. 
Dated: March 21, 2022 
 
 
 
 
 
 
 
__________________________ 
 
 
 
 
 
 
 
 
DENISE EARLE 
Case 4:20-cv-03056-DMR     Document 166-2     Filed 03/21/22     Page 2 of 2

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