Declaration Joint Declaration of Shawn M. Kennedy, Rachel Geman, and Christopher J. Cormier — Plaid Privacy (Dkt. 157.1)

Summary

Joint Declaration of Shawn M. Kennedy, Rachel Geman, and Christopher J. Cormier in support of Plaintiffs' Motion for Attorneys' Fees, Reimbursement of Expenses, and Plaintiff Service Awards, Doc. 157-1 in In re Plaid Inc. Privacy Litigation, Master Docket No. 4:20-cv-03056-DMR, in the U.S. District Court for the Northern District of California. The declarants state that their three firms served as Co-Lead Interim Class Counsel from July 29, 2020 until November 19, 2021, when the Court preliminarily appointed them Co-Lead Class Counsel. A table states total time of 5,626.5 hours and a lodestar of $4,394,236. The declaration describes an investigation that began in January 2020 and states that it led to a complaint filed on May 4, 2020 by plaintiffs James Cottle and Frederick Schoeneman.

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JOINT DECL ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR 
 
HERRERA KENNEDY LLP 
Shawn M. Kennedy (SBN 218472) 
skennedy@herrerakennedy.com 
Bret D. Hembd (SBN 272826) 
bhembd@herrerakennedy.com 
4590 MacArthur Blvd., Suite 500 
Newport Beach, CA 92660 
Tel: (949) 936-0900 
Fax: (855) 969-2050 
 
HERRERA KENNEDY LLP 
Nicomedes Sy Herrera (SBN 275332) 
nherrera@herrerakennedy.com 
1300 Clay Street, Suite 600 
Oakland, CA 94612 
Tel: (510) 422-4700 
Fax: (855) 969-2050 
 
LIEFF CABRASER HEIMANN & 
BERNSTEIN, LLP 
Rachel Geman (Pro Hac Vice) 
rgeman@lchb.com 
250 Hudson Street, 8th Floor 
New York, NY 10013-1413 
Tel: (212) 355-9500 
Fax: (212) 355-9592 
 
Co-Lead Class Counsel 
[Additional counsel on signature page] 
LIEFF CABRASER HEIMANN &  
BERNSTEIN, LLP 
Michael W. Sobol (SBN 194857) 
msobol@lchb.com 
Melissa Gardner (SBN 289096) 
mgardner@lchb.com 
Michael K. Sheen (SBN 288284) 
msheen@lchb.com 
Nicholas R. Hartmann (SBN 301049) 
nhartmann@lchb.com 
275 Battery Street, 29th Floor 
San Francisco, CA 94111-3339 
Tel: (415) 956-1000 
Fax: (415) 956-1008 
BURNS CHAREST LLP 
Christopher J. Cormier (Pro Hac Vice) 
ccormier@burnscharest.com 
4725 Wisconsin Avenue, NW, Suite 200 
Washington, DC 20016 
Tel: (202) 577-3977 
Fax: (469) 444-5002 
 
 
 
 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
IN RE PLAID INC.  
PRIVACY LITIGATION 
Master Docket No.: 4:20-cv-03056-DMR 
 
JOINT DECLARATION OF SHAWN M. KENNEDY, 
RACHEL GEMAN, AND CHRISTOPHER J. 
CORMIER IN SUPPORT OF PLAINTIFFS’ 
MOTION FOR ATTORNEYS’ FEES, 
REIMBURSEMENT OF EXPENSES, AND 
PLAINTIFF SERVICE AWARDS 
 
Date:            May 12, 2022 
Time:           1:00 p.m. 
Courtroom:  Via videoconference only 
Judge:          The Hon. Donna M. Ryu 
THIS DOCUMENT 
RELATES TO:  
ALL ACTIONS 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 1 of 68

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JOINT DECL ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR 
 
We, SHAWN M. KENNEDY, RACHEL GEMAN, and CHRISTOPHER J. CORMIER 
hereby declare as follows: 
1. 
Shawn Kennedy is a member in good standing of the California State Bar and a 
partner in the law firm of Herrera Kennedy LLP (“HK”). Rachel Geman is a member in good 
standing of the New York State Bar and a partner in the law firm of Lieff, Cabraser, Heimann & 
Bernstein, LLP (“LCHB”). Christopher Cormier is a member in good standing of the District of 
Columbia Bar and a partner in the law firm of Burns Charest, LLP (“BC”). We submit this 
declaration jointly in support of Plaintiffs’ Motion for Attorneys’ Fees, Reimbursement of 
Expenses, and Plaintiff Service Awards. Except as otherwise noted, we have personal knowledge 
of the statements contained in this declaration and, if called to testify, could and would testify 
competently to them. 
2. 
HK, LCHB, and BC served as Co-Lead Interim Class Counsel from July 29, 2020 
until November 19, 2021, when the Court preliminarily appointed them Co-Lead Class Counsel. 
(Dkts. 57, 153.) In these positions, we have had a primary role in devising the litigation and 
settlement strategies for the Class, and we have been actively and personally involved in 
prosecuting and resolving the litigation. 
OVERVIEW 
3. 
Prosecution of this complex litigation required an enormous amount of work, 
effort, and expense by HK, LCHB, and BC (collectively, “Class Counsel”) over more than two 
years. Throughout this litigation, Class Counsel devoted whatever resources were necessary to 
see it through to a successful outcome. The following table summarizes the total hours dedicated 
by Class Counsel to this action between January 2020 and January 25, 2022:  
Table 1 
Summary of Time Incurred 
Law Firm 
Total Hours 
Total Lodestar 
HK 
1,944.9 
$1,811,332.50 
LCHB 
2,080.8 
$1,296,641.00 
BC 
1,600.8 
$1,286.262.50 
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Total 
5,626.5 
$4,394,236 
 
4. 
These figures are derived from our respective time records, which are prepared 
contemporaneously in the ordinary course of business. As noted above and described in detail 
herein, the lodestar resulting from those hours is $4,394,236.  
5. 
These amounts do not include time that we have written off in the exercise of 
billing discretion upon review of our law firms’ respective time records. Only time and expenses 
that inured to the benefit of the Class and that advanced the claims resolved in the Settlement 
have been included in the time and costs presented in Class Counsel’s fee motion. 
LITIGATION HISTORY 
I. 
Discovery and Investigation of Claims, Filing of Initial Action, and Consolidated 
Amended Complaint 
6. 
This action did not result from the release of a public statement by Plaid or a news 
report. Rather, the genesis of this action was Class Counsel’s discovery of the privacy breaches 
alleged in this action, followed by several months of factual and legal investigatory work that 
Class Counsel undertook beginning in January 2020.  
7. 
As part of the investigation, Class Counsel reviewed numerous videos, message 
board posts, web pages, submissions to government regulators, podcasts, marketing materials, 
articles, and other publicly available information. Our investigation included delving into the 
history and evolution of Plaid’s business, including its founding and growth within the fintech 
industry. We developed an understanding of Plaid’s historical and current business practices, as 
well as the distinctions between its consumer-facing and industry-facing messaging. 
8. 
Class Counsel also gathered information about how Plaid’s software worked, 
including the methods Plaid used to collect data from consumers and deliver that data to its 
fintech customers. To get a fuller understanding of how Plaid’s software worked, we engaged an 
expert to analyze various aspects of the software, including the nature of the software templates 
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provided to Plaid clients and the security involved in transmitting login information through Plaid 
Link. 
9. 
Class Counsel’s investigation led to the filing of an 81-page complaint on May 4, 
2020 by plaintiffs James Cottle and Frederick Schoeneman in an action captioned Cottle et al. v. 
Plaid Inc., No. 4:20-cv-03056-DMR (the “Cottle Action”). (Dkt. 1.) Plaid initially was 
represented in the Cottle Action by attorneys from the San Francisco and New York offices of 
Gibson, Dunn & Crutcher LLP. (Dkt. 51.) After several months, Plaid substituted Gibson Dunn 
for new counsel from the San Francisco office of Cooley LLP. (Dkt. 97.) 
10. 
On July 17, 2020, Plaid, the Cottle Action plaintiffs, and plaintiffs in four 
subsequently-filed actions filed a stipulation to consolidate the cases and appoint Class Counsel 
as interim co-lead counsel under Federal Rule of Civil Procedure 23(g). (Dkt. 51.) On July 29, 
2020, the Court consolidated the Cottle Action with the four related actions (collectively, the 
“Action”), and appointed Class Counsel as interim co-lead counsel. (Dkt. 57.) On August 5, 2020, 
consolidated Plaintiffs filed the 105-page Consolidated Amended Class Action Complaint 
(“CAC”). (Dkt. 61.) 
II. 
Plaid’s Motion to Dismiss 
11. 
On September 14, 2020, Plaid filed a 38-page motion to dismiss the CAC in its 
entirety. (Dkt. 78.) Plaid argued, among other things, that (1) Plaintiffs lacked standing to pursue 
any of their claims, including because they had not sufficiently pled an injury in fact; (2) most of 
Plaintiffs’ claims were barred by relevant statutes of limitations; (3) Plaintiffs’ equitable claims 
were barred; (4) Plaintiffs failed to plead actionable claims under the Stored Communications 
Act, 18 U.S.C. §§ 2701 et seq. (“SCA”), Computer Fraud and Abuse Act, 18 U.S.C. § 1030 
(“CFAA”), or the Computer Data and Access Fraud Act, Cal. Penal Code § 502 (“CDAFA”); (5) 
Plaintiffs filed to allege economic harm under the Unfair Competition Law, Cal. Bus. & Prof. 
Code §§ 17200 et seq. (“UCL”); (6) Plaintiffs failed to plead common-law claims for invasion of 
privacy, violation of the California Constitution (Article I, Section I), or deceit; and (7) Plaintiffs 
failed to plead a claim under California’s Anti-Phishing Act of 2005, Cal. Bus. & Prof. Code 
§ 22948 et seq. (“CAPA”). 
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12. 
On November 17, 2020, Plaintiffs filed a 45-page opposition to Plaid’s motion to 
dismiss, arguing that each of the claims in the CAC was adequate under the relevant standards. 
(Dkt. 108.) On December 11, 2020, Plaid filed its 22-page reply brief. (Dkt. 111.) 
13. 
On February 11, 2021, the parties participated in a hearing on Plaid’s motion to 
dismiss. On April 30, 2021, the Court issued an order granting in part Plaid’s motion, dismissing 
with prejudice Plaintiffs’ claims for declaratory and injunctive relief and their claims under the 
SCA, CFAA, CDAFA, and UCL, and sustaining Plaintiffs’ invasion of privacy/intrusion into 
private affairs and unjust enrichment claims for a nationwide class, as well as their claims for 
deceit, violations of the California Constitution, and violations of CAPA for a California class. 
(Dkt. 125.) 
III. 
Formal and Informal Discovery 
14. 
Shortly after the Cottle Action was filed, the Court set an initial Case Management 
Conference for August 5, 2020. (Dkt. 10.) On July 27, 2020, the Cottle Action plaintiffs filed an 
administrative motion to continue the initial CMC, explaining that it was necessary to do so 
pending the Court’s decision on the parties’ then-pending stipulation to consolidate the related 
actions, but that Plaid refused to agree to a short continuance and instead indicated that it would 
only agree to a continuance until a date after the Court ruled on a motion to dismiss. (Dkt. 54.) 
Plaid thus sought to indefinitely delay discovery. But on July 29, 2020, the Court granted 
Plaintiffs’ request, continuing the initial CMC to October 7, 2020. (Dkt. 58.) 
15. 
On September 14, 2020, Plaid filed a motion styled as an “Administrative Motion 
to Continue Case Management Conference,” in which Plaid requested that the Court continue the 
initial CMC and related deadlines, including the Rule 26(f) report and initial disclosures, until 
after the Court ruled on the motion to dismiss. (Dkt. 83.) Plaid thus made a second attempt to stay 
discovery pending its motion to dismiss. Plaintiffs opposed Plaid’s motion, arguing that discovery 
should be allowed to proceed on schedule. On September 25, 2020, the Court denied Plaid’s 
motion, finding that it failed to meet its burden to demonstrate that a discovery stay was 
appropriate. (Dkt. 89.) 
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16. 
On October 7, 2020, the Court conducted the first Case Management Conference. 
At the CMC, Plaid renewed its request that the Court stay discovery pending its ruling on Plaid’s 
motion to dismiss. Class Counsel again opposed Plaid’s request, asking the Court to allow 
discovery to proceed. The Court again denied Plaid’s request, ruling that discovery was open. 
17. 
On October 27, 2020, Plaintiffs served a First Set of Requests for Production to 
Plaid. On March 19, 2021, Plaintiffs served Plaid with a First Set of Requests for Admission and 
a First Set of Interrogatories. On April 20, 2021, Plaintiffs served a Second Set of Requests for 
Production to Plaid. In all, Class Counsel served—and Plaid responded to—57 document 
requests, 21 interrogatories, and 51 requests for admissions. 
18. 
In responding to Plaintiffs’ written discovery requests, Plaid initially avoided 
committing to produce responsive documents and information, instead asserting objections and 
stating that it would meet and confer with Class Counsel regarding the scope of terms used in 
Plaintiffs’ requests.  
19. 
As a result, Class Counsel embarked upon a months-long process of meeting and 
conferring with Plaid about its obligations to produce relevant documents and information as 
requested. Class Counsel began that process on December 23, 2020, and it did not conclude until 
May 8, 2021. Over that period, Class Counsel participated in dozens of telephonic and written 
meet-and-confer sessions, expending a great deal of time and effort to hold Plaid accountable for 
its obligations to produce key relevant documents. Class Counsel pushed throughout that time for 
documents and information related to issues such as the nature of Plaid’s software and data 
collection practices, the data Plaid provided to its clients, the revenues Plaid earned, the internal 
policies and procedures in place at Plaid, the consumer disclosures employed by Plaid at various 
points, and the agreements between Plaid and various financial institutions as well as between 
Plaid and its clients. 
20. 
These issues were highly contested. Plaid eventually agreed to produce certain 
categories of documents, while continuing to push back on others. When it appeared that the 
parties had reached an impasse, Class Counsel ultimately teed up motions to compel on several 
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issues. But just before those motions would have been filed, Plaid agreed to multiple 
compromises and to produce the documents Plaintiffs requested. 
21. 
Plaid ultimately produced over 12,000 pages of documents, including internal 
policies and procedures, agreements, correspondence, investigatory materials, client lists, and 
detailed financial information.  
22. 
During this same time period, Class Counsel commenced third-party discovery as 
well, subpoenaing JP Morgan Chase and starting discussions with other banks. Class Counsel 
also responded to a set of document requests served by Plaid. In addition, Class Counsel engaged 
a forensic consultant to preserve data from the named Plaintiffs, and oversaw the preservation of 
data from several Plaintiffs’ personal mobile devices. 
23. 
Class Counsel also sought and received significant discovery from Plaid as part of 
the mediation and negotiation process that led to the Settlement. In response to informal 
discovery requests, Plaid provided further information, internal documents, and data that shed 
light on the nature and function of Plaid’s software and business practices during the class period, 
its finances, and the size and scope of the potential class, among other things. Prior to the 
mediation, for example, the parties participated in a technology tutorial session with Judge 
Gandhi, in which Plaid’s businesspeople explained aspects of Plaid’s technology and business 
model. After reaching agreement on settlement terms with Plaid, Class Counsel sought and 
received confirmatory discovery from Plaid as well. 
24. 
As a result of the significant discovery provided by Plaid, Class Counsel were able 
to properly assess the value of the Class’s claims and negotiate a fully-informed settlement that 
maximizes the financial recovery available to the Class and provides important injunctive relief 
designed to substantially remedy the alleged misconduct going forward while avoiding litigation 
risks that were brought to light in the process. 
IV. 
Mediation and Settlement 
25. 
Between February 2021 and July 2021, the Parties engaged in lengthy and 
contentious arm’s-length negotiations to resolve the claims in the Action. On February 16, 2021, 
the Parties engaged in a full-day mediation session with the Hon. Jay Gandhi (ret.). Prior to the 
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mediation, the parties prepared detailed mediation briefs outlining their positions on the strengths 
and weaknesses of the case. The Parties went into the mediation with substantially different 
positions relating to appropriate settlement terms and did not resolve the Action at the initial 
mediation session. 
26. 
For the next several months, while the parties continued to litigate, they continued 
to engage in the mediation process with Judge Gandhi, who helped bridge the gap between their 
positions.  
27. 
The parties held another mediation session on April 13, 2021. Before and after that 
mediation session, the parties engaged in extensive communications with each other and Judge 
Gandhi regarding points of contention and additional information required to move discussions 
forward. 
28. 
On June 7, 2021, Judge Gandhi made a mediator’s proposal for a class-wide 
settlement for $58 million subject to the parties’ negotiation of, and agreement to, appropriate 
injunctive relief. That recommendation was accepted by all parties in a double-blind process on 
June 11, 2021. Over the next six weeks, the parties negotiated the terms of a long-form settlement 
agreement, including injunctive relief. These negotiations ultimately resulted in the Settlement 
Agreement, which was executed on July 30, 2021.  
29. 
The negotiations of the Settlement Agreement were intense and included multiple 
lengthy telephone conferences and extensive email correspondence, as well as the exchange of 
multiple drafts of the proposed Settlement Agreement and related materials.  
30. 
During the negotiation process, the parties were at many times far apart and often 
at odds. The mediator’s direct resolution of disputes was required, at times, to prevent the 
discussions from collapsing altogether.   
31. 
Throughout the mediation and settlement process, Class Counsel vigorously 
pursued the best interests of the putative Class. In negotiating the Settlement Agreement, the 
parties negotiated at arms’ length and did not engage in substantive negotiation about or reach 
any agreement concerning the amount of attorneys’ fees that should be awarded, reimbursement 
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of expenses, or class representative service awards. At no point did Class Counsel seek to 
advance their own interests over those of the Class. 
32. 
Certain differences between the proposed litigation classes reflected in the CAC 
and the Settlement Class reflect Class Counsel’s determination, based upon information learned 
through formal and informal discovery, that (1) the challenged aspects of Plaid’s software and 
conduct apply to the users of a broader set of fintech apps and services than those enabling 
payments and money transfers; and (2) the “OAuth Process” and “Managed OAuth Process” that 
Plaid employed with certain financial institutions at certain points in time should be excluded 
from the Class. The Settlement Class is thus broader in that it includes users of more fintech apps 
and narrower in that it excludes users who connected to their accounts using a different process 
than was described in the CAC. 
33. 
On August 6, 2021, Class Counsel filed the Motion for Preliminary Approval of 
Class Action Settlement, including a description of the monetary and injunctive relief provided by 
the Settlement and a notice plan prepared by Angeion Group, LLC. (Dkts. 137, 138, 139.) 
Following a hearing on September 30, 2021, the Court granted preliminary approval of the 
Settlement on November 19, 2021. (Dkt. 153.) 
34. 
Should the Court approve the Settlement, Class Counsel will continue to 
vigorously represent the interests of the Class throughout settlement administration. 
CHARACTERISTICS OF THE CLASS 
35. 
Class Counsel estimates that the Settlement Class reflected in the Settlement 
Agreement includes approximately 98 million individuals. That estimate is based upon an internal 
analysis performed by Plaid of its own data in 2020. 
WORK PERFORMED BY CLASS COUNSEL 
36. 
Each of our law firms has categorized their time spent in this litigation according 
to the nature of the task. Exhibits A, B, and C hereto are summaries describing the amount of 
time spent by each attorney and staff member whose time is included in Class Counsel’s total 
lodestar, as divided among each of the following ten categories: 
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37. 
The Lead Counsel Calls / Meetings category includes communications and 
conferences between and among Class Counsel. 
38. 
The Investigations / Factual Research category includes all work and research 
required to develop knowledge of facts related to the claims alleged on behalf of the Class; 
research concerning the impact of Plaid’s conduct on Plaintiffs and putative Class members; 
communications with the Class Representatives regarding the allegations included in the initial 
complaints and the CAC; and ongoing analysis of relevant technical and other developments 
throughout the course of the litigation. 
39. 
The Discovery (Draft / Respond / Meet & Confer) category includes work to 
form a discovery plan; drafting of discovery requests and responses; meeting and conferring on 
discovery responses; communications and conferences regarding evidence and information 
provided by Plaid through formal and informal discovery; planning, drafting and serving third-
party discovery; meeting and conferring with third parties’ counsel; and coordination and 
communication with the Class Representatives and, where applicable, their counsel regarding the 
location of potentially relevant evidence and information, evidence preservation, and the 
provision of personal information. 
40. 
The Discovery (Document Review) category includes review and analysis of 
documents and data produced by Plaid through formal and informal discovery. 
41. 
The Pleadings, Briefs, Motions category includes drafting, review, and filing of 
all pleadings, briefs, and motions before the Court, including without limitation the CAC, status 
reports and case management statements, and the opposition to Plaid’s motion to dismiss. 
42. 
The Court Appearances & Preparation category includes all conferences and 
other tasks undertaken to prepare for hearings, case management conferences, and other 
appearances before the Court; the analysis and preparation of materials for use in Court 
appearances; and time spent in appearances before the Court. 
43. 
The Settlement category includes strategy, analysis, correspondence, and 
conferences related to settlement negotiations; drafting of mediation briefs, term sheets, and the 
Settlement Agreement; preparation and conduct of each mediation and settlement conference; 
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preparation and filing of the settlement approval briefing and associated exhibits; evaluating and 
selecting a Settlement Administrator; oversight of the scope and implementation of the notice 
program; research and selection of proposed cy pres recipients; and communications with defense 
counsel, Class Representatives, class members, and the Court regarding the Settlement. 
44. 
The Case Management & Litigation Strategy category includes time spent 
developing and furthering a cohesive and comprehensive case strategy and goals; analysis of 
relevant developments in case law and other areas; management of the case file, including 
administrative work; the allocation of work among counsel, and all related oversight. 
45. 
The Legal Research category includes research and analysis regarding substantive 
and procedural legal issues. 
46. 
The Experts / Consultants category includes time incurred to identify and retain 
consulting experts, as well as consultations to assist with preparation of the initial complaint in 
the Cottle Action. 
47. 
We, and attorneys under our supervision, reviewed the time records kept by our 
respective law firms for purposes of this declaration and assigned each time entry to one of the 
ten categories described above, which were distributed by Class Counsel to all Plaintiffs’ counsel 
in this litigation. The total hours and lodestar incurred by Class Counsel for each of the ten 
categories are detailed in Table 2 below.  
Table 2 
Lodestar and Rates by Category 
Category 
Total Hours 
Total Lodestar 
Lead Counsel Calls / Meetings 
390.8 
$332,359.00 
Investigations / Factual Research 
462.7 
$392,851.50 
Discovery (Draft / Respond / Meet & Confer) 
714.4 
$528,447.50 
Discovery (Document Review) 
39.1 
$32,562.50 
Pleadings, Briefs, Motions 
1,330.2 
$1,022,038.50 
Court Appearances & Preparation 
297.8 
$241,689.00 
Settlement 
1,055.1 
$842,240.50 
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Case Management & Litigation Strategy 
817.2 
$571,284.50 
Legal Research 
433.2 
$362,315.00 
Experts / Consultants 
86 
$68,448.00 
Totals 
5,626.5 
$4,394,236 
 
48. 
These submitted hours do not include every hour reported, even by Class Counsel. 
They do not include timekeepers from Class Counsel who billed less than 10 total hours. They 
also do not include time from other counsel representing named Plaintiffs, who made 
contributions to the Action, but collectively submitted a relatively small number of hours 
compared to Class Counsel. The above amounts also do not include the additional time that Class 
Counsel will spend going forward in seeking approval of, and implementing, the Settlement, 
including responding to inquiries from Class Members and overseeing distribution of the 
Settlement Fund. Based on prior experience, these responsibilities may require a significant 
further time commitment from Class Counsel. If there are objections to the Settlement and 
subsequent appeals, those commitments and responsibilities may extend for several more years. 
49. 
The time that Class Counsel spent on this case has been completely contingent 
on the outcome. We prosecuted this case on a purely contingent basis and agreed to advance all 
necessary expenses, to the exclusion of other fee-generating work, knowing that we would 
receive a fee and be reimbursed our expenses only if we obtained meaningful relief on a class-
wide basis. 
50. 
Additional work will be required to obtain final approval of the Settlement; 
to protect the Settlement on appeal (if any appeals are lodged); to respond to inquiries from Class 
Members about their rights and relief provided by the Settlement; to oversee and monitor Plaid’s 
compliance with the injunctive relief provided by the Settlement; to oversee the distribution and 
allocation of any cy pres funding awarded by the Court; and to ensure and report on compliance 
by each cy pres recipient with the terms of the Settlement.  
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51. 
Based on our experience with other class actions and complex cases, we believe 
that the time expended in connection with this matter was necessary to ensure the success of the 
action and reasonable in amount, particularly given the result achieved by the Settlement and the 
novelty and complexity of the litigation.  
CLASS COUNSEL’S HOURLY RATES 
52. 
This case involves Plaid’s actions in collecting and handling some of the most 
private of all consumer information: banking login credentials and detailed financial data for tens 
of millions of people. At issue are novel and untested claims for violation of CAPA (with 
attendant statutory penalties) as well as claims for invasion of privacy/intrusion into private 
affairs, unjust enrichment, deceit, and violations of the California Constitution. These issues were 
disputed in a highly technical context that required our attorneys and consulting experts to apply 
expertise in the functioning of the Plaid Link interface in various fintech apps, Plaid’s use of 
different methods for collecting data from financial institutions, and Plaid’s delivery and use of 
banking data to its clients. These and other difficult issues implicated by these claims required us 
to research and devise litigation strategies to move the case through motion practice and 
contentious merits discovery towards trial, without the certainty of ever receiving compensation. 
The hourly rates utilized in the lodestar calculation include no risk multiplier. 
53. 
The rates sought for each law firm’s attorneys and staff are the firm’s current 
commercial billing rates, which have been approved and paid in other cases, and are supported by 
Class Counsel’s extensive and specialized experience in these types of cases and recognized 
expertise, as described below for each of HK, LCHB, and BC, respectively. 
Herrera Kennedy (by Shawn Kennedy) 
54. 
HK is a litigation firm that routinely leads high-stakes, novel, and complex 
contingency and class action cases. HK’s partners have been entrusted with leadership roles in 
significant antitrust and consumer class actions and have discovered, initiated, and pursued 
groundbreaking qui tam actions alleging anticompetitive conduct by some of the largest and most 
well-represented companies in the world. Over the last three years, HK’s partners have recovered 
over $200 million in damages on behalf of injured consumers in exceedingly large and 
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complicated class actions. More information on HK can be found at the firm’s website, 
http://herrerakennedy.com. 
55. 
HK’s audited lodestar of $1,811,332.50 through January 25, 2022, reflects 1,944.9 
hours of work by highly qualified attorneys. This case was litigated by HK partners Shawn 
Kennedy, Nico Herrera, and Bret Hembd, with additional work contributed by Laura Seidl and 
Andrew Purdy. 
56. 
Shawn Kennedy received his JD in 2001 from Duke University School of Law. 
He has over 20 years of experience handling class actions and other complex litigation matters. 
He has litigated numerous high-stakes consumer class actions involving securities, antitrust and 
consumer fraud claims. In addition, as the founder of technology companies in the legal and 
financial industries, he has extensive experience and substantive knowledge regarding cloud-
based technology; software development; security and privacy; and data storage and analytics. 
This experience and knowledge proved invaluable in allowing him to uncover Plaid’s wrongful 
conduct alleged in this action. He had primary responsibility for guiding the investigation and 
development of the factual allegations and claims in this case. Prior to joining HK, he practiced 
with international law firms Morgan, Lewis & Bockius LLP, and Howrey LLP, where he was 
selected as a “Rising Star” by Super Lawyers and was selected as Attorney of the Year by the 
Public Law Center. 
57. 
Nicomedes Sy Herrera received his JD in 1997 from Columbia Law School, 
where he was a Harlan Fiske Stone Scholar. He is a strategic litigator with over 24 years of 
experience litigating a broad range of complex, high-impact privacy, antitrust, and consumer class 
actions, derivative suits, and qui tams. He investigated and commenced a groundbreaking series 
of billion dollar qui tam lawsuits against some of the largest pharmaceutical manufacturers based 
on the drug companies’ assertion of fraudulently-procured patents to exclude generic competition. 
Prior to joining HK, he also held senior executive and general counsel positions for several New 
York and Chicago-based financial services firms. He has been selected as a “Super Lawyer” and 
a “Rising Star” by Super Lawyers. 
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58. 
Bret D. Hembd received his JD from Yale Law School in 2010, where he served 
as an Editor of The Yale Law Journal. He is an accomplished litigator who represents individuals 
and companies in a broad array of business litigation in state and federal court. With his partners, 
he has litigated high-stakes consumer class actions and qui tam lawsuits in federal courts across 
the nation. Prior to joining HK, he practiced at Irell & Manella LLP. He has been selected as a 
“Rising Star” by Super Lawyers each year from 2017 to 2022. 
59. 
Laura E. Seidl received her JD from New York Law School in 2008. She is a 
skilled litigator with a history of outstanding success representing people from all walks of life. 
Her clients have ranged from private equity investors litigating complex derivative lawsuits with 
hundreds of millions of dollars at stake to individuals suffering homelessness during the Bay Area 
housing crisis.  
60. 
HK’s customary rates, which were used for purposes of calculating HK’s lodestar 
reflected in Exhibit A, are consistent with prevailing rates in this District and have been billed to 
and paid by HK’s hourly clients. See also In re Capacitors Antitrust Litig., No. 3:17-md-02801-
JD, 2020 U.S. Dist. LEXIS 209514, at *64–65 (N.D. Cal. Nov. 7, 2020) (approving HK partner’s 
fees at prior firm as part of total award of $69.6 million in fees); In re Restasis (Cyclosporine 
Ophthalmic Emulsion) Antitrust Litig., No. 18-MD-2819 (NG) (LB), 2020 U.S. Dist. LEXIS 
198674, at *26–27 (E.D.N.Y. Oct. 6, 2020) (approving HK partner’s fees at prior firm as part of 
total award of $16.4 million in fees); In re HP Printer Firmware Update Litig., No. 5:16-cv-
05820-EJD, 2019 U.S. Dist. LEXIS 108959, at *8–9 (N.D. Cal. June 28, 2019) (approving HK 
partner’s fees at prior firm as part of total award of $2.75 million in fees).  
Lieff, Cabraser, Heimann & Bernstein (by Rachel Geman) 
61. 
LCHB is one of the oldest, largest, most-respected, and most-successful class 
action firms in the country, and has recovered billions of dollars for class members.  The firm 
brings to the table extensive experience litigating and settling consumer and privacy class actions 
and other complex matters, and has played a lead role in prosecuting numerous privacy class 
actions, including: In re Google Location History Litigation, No. 18-05062 (N.D. Cal.) (Co-Lead 
Class Counsel); Campbell v. Facebook, No. 13-05996 (N.D. Cal.) (Co-Lead Class Counsel); 
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Perkins v. LinkedIn Corp., No. 13-04303 (N.D. Cal.) (Co-Lead Class Counsel); Corona v. Sony 
Pictures Entertainment, Inc., No. 14-09600 (C.D. Cal.) (Co-Lead Class Counsel); Ebarle et al. v. 
LifeLock Inc., No. 15-00258 (N.D. Cal.) (Co-Lead Class Counsel); and Matera v. Google LLC, 
No. 15-04062 (N.D. Cal.) (Co-Lead Class Counsel).  More information on LCHB can be found at 
the firm’s website, www.lieffcabraser.com. 
62. 
LCHB’s audited lodestar of $1,296,641 through January 25, 2022, reflects 
2,080.80 hours of work by highly qualified attorneys, as addressed in the following paragraphs.  
63. 
Rachel Geman received her J.D. in 1997 from Columbia Law School, with 
honors. In addition to serving as Co-Lead counsel in this matter, Ms. Geman is active in the 
firm’s consumer, false claims, and employment practice groups. She presently serves on the 
Plaintiffs’ Steering Committee in contaminated drug litigation (Valsartan) and is proposed co-
lead class counsel for medical monitoring; represents a certified class of women in employment 
discrimination litigation against Goldman Sachs; is co-lead counsel in kickback litigation against 
AbbVie; and represents multiple whistleblowers in complex matters. Ms. Geman has been co-
lead counsel or counsel of record in consumer and other complex litigation that has resolved in 
the N.D. Cal.  See In re: Bank of Am. Credit Protection Marketing & Sales Practices Litig., No. 
11-02269 (N.D. Cal.) (Ms. Geman and LCHB were co-lead class counsel); Brazil v. Dell, No. 7-
01700 (N.D. Cal.) (LCHB co-lead class counsel); and In re Axa Rosenberg Inv. Litig., No. 11-
00536 (N.D. Cal.) (LCHB co-lead class counsel)]. Ms. Geman chairs NELA-NY’s amicus 
committee and is a frequent writer and speaker on topics in complex litigation. Ms. Geman has 
been selected for inclusion by peers in The Best Lawyers in America in the field of “Employment 
Law - Individuals” from 2012-2022. She was named among the “Lawdragon 500 Leading 
Plaintiff Financial Lawyers in America” in 2021, “Lawdragon 500 Leading Plaintiff Employment 
Lawyers in America” from 2018-2021, and “Lawdragon 500 Leading Plaintiff Consumer 
Lawyers” in 2019.   
64. 
Michael Sobol is the Chair of LCHB’s Cybersecurity and Data Privacy practice 
group. Mr. Sobol received his J.D. in 1989 from Boston University School of Law. Since joining 
LCHB in 1997, Mr. Sobol has represented plaintiffs in numerous nationwide consumer 
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protection, data privacy and other class actions and complex matters. Mr. Sobol is widely 
recognized for his expertise and substantial experience in the area of digital privacy and security, 
including most recently by the Daily Journal as a “Top Cyber/Artificial Intelligence Lawyer,” 
2018-2019; by Law360 as “MVP for Cybersecurity and Privacy” in 2017; and by the National 
Law Journal as “Cybersecurity & Data Privacy Trailblazer” in 2017. 
65. 
Melissa Gardner received her J.D. in 2011 from Harvard Law School. Ms. 
Gardner joined LCHB as an associate in 2012 and became a partner at the firm in 2019. Ms. 
Gardner focuses her practice on representing plaintiffs in consumer protection and digital privacy 
class action litigation, and has significant experience with class action consumer privacy litigation 
involving claims under the Wiretap Act. Ms. Gardner has been selected by Super Lawyers as a 
“Rising Star for Northern California” each year from 2017-2020. 
66. 
Mike Sheen received his J.D. in 2012 from the University of California, Berkeley. 
His practice centers on securities and financial fraud and consumer and data privacy fraud 
matters. Prior to joining the firm in 2018, Mr. Sheen served as a law clerk to the Honorable Dale 
A. Drozd of the U.S. District Court for the Eastern District of California. He was also an associate 
at Milbank, Tweed, Hadley & McCloy LLP, where his practice focused on intellectual property 
and commercial litigation. 
67. 
Rhea Ghosh received her J.D. in 2016 from the University of Pennsylvania Law 
School. Before coming to Lieff Cabraser, Ms. Ghosh served as a judicial clerk to the Honorable 
Charles S. Haight, Jr. of the Southern District of New York and also was an associate at Kirkland 
& Ellis LLP.  Presently, Ms. Ghosh is clerking on the Tenth Circuit Court of Appeals. 
68. 
Madeline Gomez received her J.D in 2015 from Columbia Law School where she 
served as the Executive Editor and Notes Editor for the Columbia Journal of Gender and Law and 
won the Myra Bradwell Award for the best student note on women and the law and the Pauline 
Berman Heller Prize for the most outstanding record of academic achievement in the service of 
gender equality. Ms. Gomez served as a law clerk for the Honorable Martha Craig Daughtrey of 
the U.S. Court of Appeals for the Sixth Circuit. Ms. Gomez worked on this case in its early 
stages. 
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69. 
Nicholas Hartmann received his J.D. in 2014 from the University of California, 
Irvine School of Law. Prior to joining the firm, Mr. Hartmann served as a judicial clerk to the 
Honorable Andrew J. Peck of the U.S. District Court for the Southern District of New York and 
to the Honorable Eric L. Clay of the U.S. Court of Appeals for the Sixth Circuit. He was also an 
associate at Patterson Belknap Webb & Tyler LLP, New York City. Mr. Hartmann began work 
on this case when it was in its settlement posture. 
70. 
Ariana Delucchi is a paralegal. She obtained her Bachelor of Arts from the 
University of San Francisco in 2010 and her Paralegal Studies Certificate from San Francisco 
State University in 2017. 
71. 
LCHB’s customary rates, which were used for purposes of calculating LCHB’s 
lodestar reflected in Exhibit B, are consistent with prevailing rates in this District and repeatedly 
have been approved by federal courts in this Circuit: See, e.g., In re Volkswagen “Clean Diesel” 
Mktg., Sales Practices, & Prod. Liab. Litig., MDL 2672, Dkt. No. 3489 (N.D. Cal. July 21, 2017) 
(approving in lodestar cross-check rates of Class Counsel, including LCHB, which ranged “from 
$250 to $1,650 for partners, $185 to $850 for associates, and $65 to $390 for paralegals”); In re 
Intuit Data Litig., No. 15-1778, 2019 WL 2166236, at *2 (N.D. Cal. May 15, 2019) (awarding 
requested attorneys’ fees); Campbell et al. v. Facebook, Inc., No. 13-05996, Dkt. No. 253 (N.D. 
Cal. August 18, 2017) (approving LCHB rates); Allagas v. BP Solar Int’l, Inc., No. 14-00560, 
2016 WL 9114162, at *2 (N.D. Cal. Dec. 22, 2016) (approving LCHB rates as “in line with 
prevailing rates in this District”); Perkins v. LinkedIn Corp., No. 13-CV-04303, 2016 WL 
613255, at *15 (N.D. Cal. Feb. 16, 2016) (approving LCHB rates); In re High-Tech Employee 
Antitrust Litig., No. 11-02509, Dkt. No. 1112 (N.D. Cal. Sept. 2, 2015) (approving LCHB rates); 
In re TracFone Unlimited Serv. Plan Litig., 112 F. Supp. 3d 993, 1009 (N.D. Cal. 2015) 
(awarding requested attorneys’ fees); Steinfeld v. Discover Financial Services, No. 3:12-01118 
(N.D. Cal. Mar. 31, 2014) (“Class counsel have submitted declarations that show the hourly rates 
that they have requested are reasonable and have provided the Court with information about other 
cases that approved their rates.”); In re: Toyota Motor Corp. Unintended Acceleration Marketing, 
Sales Practices, and Products Liability Litig., No. 10-ml-02151, Dkt. No. 3933 (C.D. Cal. June 
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24, 2013) (awarding requested fees and finding that “[c]lass counsel’s experience, reputation, and 
skill, as well as the complexity of the case” justified billing rates). 
Burns Charest LLP (by Christopher Cormier) 
72. 
BC is a boutique trial firm that represents individuals, businesses, and classes in 
complex, high-value disputes, primarily in the fields of antitrust, privacy, intellectual property, 
energy, and mass torts. Founded in 2015 by former Susman Godfrey LLP partners and associates, 
its partnership now includes former partners of other prominent firms like Arnold & Porter LLP 
and Cohen Milstein Sellers & Toll PLLC. With offices in Dallas, New Orleans and Washington, 
DC, the firm has quickly gained a reputation as one of the preeminent complex plaintiff-side 
litigation firms in the nation. The firm has obtained judgments and settlements totaling well into 
the hundreds of millions of dollars for their clients as lead counsel in various class actions and 
mass torts and for individual and corporate clients in various business disputes. The firm and its 
lawyers have been repeatedly ranked by preeminent legal publications such as Benchmark 
Litigation, Best Lawyers in America, Chambers and Partners, Global Competition Review, 
Lawdragon, and Super Lawyers. More information on BC can be found at the firm’s website, 
https://www.burnscharest.com. 
73. 
BC’s audited lodestar of $1,286,262.50 through January 25, 2022, reflects 
1,600.80 hours of work by highly qualified attorneys and support staff. This case primarily was 
litigated by BC partners Christopher J. Cormier and Warren T. Burns, with additional work 
contributed by associates and paralegals. 
74. 
Christopher J. Cormier has led BC’s investigation, litigation, and settlement 
efforts in this case. He graduated magna cum laude from American University’s Washington 
College of Law in 2002 and earned a BA in Government from the University of Virginia in 1999. 
He has 20 years of experience handling antitrust, privacy and other class actions as well as 
representing business clients in high-value commercial litigation. After spending the first 16 years 
of his career as an associate and partner at Cohen Milstein Sellers & Toll PLLC, he moved to BC 
in 2018. He has served as court-appointed co-lead counsel in numerous antitrust class actions 
resulting in successful settlements and verdicts exceeding $1.5 billion, including In re Urethane 
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Antitrust Litigation (D. Kan.), where he served on the trial team that secured the largest price-
fixing verdict in the history of the Sherman Antitrust Act. Federal courts across the country also 
have personally appointed him co-lead counsel in various successful antitrust and other class 
actions. A leading publication notes that he is “lauded as ‘an excellent competition plaintiff 
lawyer’ who is regularly engaged in high-value antitrust proceedings before state and federal 
courts.” He has been named to the Lawdragon 500 Leading Plaintiff Financial Lawyers guide 
(2021) and the Lawdragon 500 Leading Plaintiff Consumer Lawyers guide (2021), honored as 
one the globe’s top plaintiffs’ antitrust lawyers in the Global Competition Review’s Who’s Who 
Legal: Competition (2020), selected to the Best Lawyers in America (2020-2022), called a 
“Rising Star” in the field of Antitrust Litigation by Super Lawyers (2016-2017), and recognized 
by Benchmark Plaintiff as an Antitrust Litigation Star (2013-2015). 
75. 
Warren T. Burns graduated summa cum laude and Order of the Coif in 2004 
from Tulane Law School, where he served as Editor in Chief of the Tulane Law Review. After 
law school, he clerked for the Hon. Paul J. Kelly, Jr. on the U.S. Court of Appeals for the Tenth 
Circuit, and then joined Susman Godfrey LLP, where was an associate and then partner. He co-
founded BC in 2015 and serves as the firm’s co-managing partner. He has served as co-lead 
counsel in numerous antitrust and other class actions and as counsel for numerous individuals and 
companies in commercial litigations and arbitrations. He has obtained settlements and verdicts for 
his clients well into the hundreds of millions of dollars. He is an elected member of the American 
Law Institute, is a Fellow of the American Bar Foundation, and sits on the Board of Advisory 
Editors of the Tulane Law Review. He has been honored by the following legal publications: 
Texas Rising Stars (2011-2015), Texas Super Lawyers (2019-2021), International Who’s Who of 
Competition Lawyers (2014-2021), Top 100 National Trial Lawyers (2015-2016, 2020), Best 
Lawyers in Dallas (2020), Best Lawyers in America (2019-2022), Lawdragon 500 Leading 
Plaintiff Consumer Lawyers (2021), and Lawdragon 500 Leading Plaintiff Financial Lawyers 
(2021).  
76. 
BC’s customary rates, which were used for purposes of calculating BC’s lodestar 
reflected in Exhibit C, are consistent with prevailing rates in this District and elsewhere and have 
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been billed to and paid by BC’s clients. See, e.g., In re EpiPen (Epinephrine Injection, USP) 
Marketing, Sales Practices and Antitrust Litig., MDL No. 2785, 2021 WL 5369798, at *4-5 (D. 
Kan. Nov. 17, 2021) (granting requested attorney fees representing specified multiplier of hourly 
rates of Burns Charest and other co-lead counsel in class action settlement); In re Anadarko Basin 
Oil and Gas Lease Antitrust Litig., No. CIV-16-209-HE, 2019 WL 1867446, at *1-3 (W.D. Okla. 
Apr. 25, 2019) (granting requested attorney fees representing specified multiplier of hourly rates 
of Burns Charest and other co-lead counsel set forth in co-lead counsel declaration in class action 
settlement). 
EXPENSES INCURRED BY PLAINTIFFS’ COUNSEL 
77. 
Class Counsel seek reimbursement of $115,920.21 in litigation expenses. As 
detailed in Exhibit D, to date HK has incurred expenses totaling $33,052.40; LCHB has incurred 
expenses totaling $48,857.80; BC has incurred expenses totaling $27,843.03; these expenses are 
reflected in our respective books and records as maintained in the ordinary course of business. As 
also detailed in Exhibit D, the other counsel representing named Plaintiffs have reported expenses 
totaling $6,166.98.  
78. 
The expenses incurred by Plaintiffs’ counsel include consultant fees, mediation 
costs, and other customary litigation expenses. Table 3 below provides an overview of those 
expenses broken down by expense category: 
Table 3 
Expenses by Category 
Category 
Cumulative Expense 
Electronic Research (Lexis/Westlaw/Pacer) 
$21,892.09 
Court Costs – Filing Fees 
$4,530.00 
Federal Express/Overnight Delivery 
$72.20 
Photocopies – In House 
$469.60 
Photocopies – Outside 
$5,504.60 
Air Travel 
$583.22 
Meals 
$18.43 
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Deposition Costs 
$82.58 
Service of Process Fees 
$100.50 
Telephone / Fax 
$374.34 
Experts / Consultant Fees 
$33,330.40 
Mediation Expenses 
$39,333.59  
Electronic Database Charges 
$8,820 
Other Charges 
$808.66 
Total 
$115,920.21 
 
TIME AND EFFORT BY PLAINTIFFS 
79. 
In addition to the time and expenses Class Counsel incurred in this action, the 
Class Representatives have spent considerable time and effort in their pursuit of this litigation and 
in seeking to advance the legal rights and interests of the Class, including time spent in fact-
finding interviews with Plaintiffs’ counsel for the CAC, discussing this litigation with Plaintiffs’ 
counsel, and communicating with Class Counsel about the proposed settlement. Class 
Representatives also participated in discovery by submitting information, declarations, and other 
evidence, including electronic devices for forensic imaging, as requested by Class Counsel.  
80. 
Attached as Exhibit E are true and correct copies of declarations from each of the 
eleven Class Representatives.  
* * * 
81. 
For the foregoing reasons, and those set forth in Plaintiffs’ Motion for Attorneys’ 
Fees, Expenses, and Plaintiff Service Awards, Plaintiffs respectfully request that the Court award 
Class Counsel $14,500,000 in fees and $115,920.21 in expenses pursuant to Federal Rule of Civil 
Procedure 23(h), to be allocated by Co-Lead Class Counsel among HK, LCHB, BC, and 
additional counsel that performed work inuring to the benefit of the Class, and Plaintiff Service 
Awards in the total amount of $55,000.  
 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 22 of 68

1 
2 
3 
4 
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 - 
JOINT DECL ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR  
 
I declare under penalty of perjury that the foregoing is true and correct as to all matters of 
which I have personal knowledge. Executed this 28th day of January, 2022, in Rancho Santa 
Margarita, California. 
 
         /s/ Shawn Kennedy 
 
Shawn M. Kennedy 
 
I declare under penalty of perjury that the foregoing is true and correct as to all matters of 
which I have personal knowledge. Executed this 28th day of January, 2022, in New York, New 
York. 
 
        /s/ Rachel Geman 
 
Rachel Geman 
 
I declare under penalty of perjury that the foregoing is true and correct as to all matters of 
which I have personal knowledge. Executed this 28th day of January, 2022, in Washington, D.C. 
 
        /s/ Christopher Cormier 
 
Christopher J. Cormier 
 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 23 of 68

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT A 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 24 of 68

Hours By Category
Timekeeper
Lead Counsel Calls / 
Meetings 
Investigations / 
Factual Research 
Discovery (Draft / Respond 
/ Meet & Confer)
Discovery (Document 
Review)
Pleadings, Briefs, 
Motions 
Court Appearances & 
Preparation 
Settlement
Case Management & 
Litigation Strategy
Legal Research 
Experts / 
Consultants
TOTALS
Shawn Kennedy
98.30
153.50
96.20
12.00
477.10
79.40
130.20
40.70
186.90
11.40
1,285.70
Bret Hembd
69.30
23.90
17.10
81.30
2.50
39.40
19.70
37.70
9.90
300.80
Nicomedes Herrera
69.80
34.40
18.80
40.50
3.60
43.20
22.30
8.60
16.40
257.60
Andrew Purdy
19.70
9.90
21.60
3.60
4.00
0.70
59.50
Laura Seidl
18.10
4.60
4.90
13.00
0.70
41.30
TOTALS
275.20
221.70
132.10
12.00
625.10
90.40
225.80
86.30
237.90
38.40
1,944.90
Lodestar By Category
Timekeeper
Lead Counsel Calls / 
Meetings 
Investigations / 
Factual Research 
Discovery (Draft / Respond 
/ Meet & Confer)
Discovery (Document 
Review)
Pleadings, Briefs, 
Motions 
Court Appearances & 
Preparation 
Settlement
Case Management & 
Litigation Strategy
Legal Research 
Experts / 
Consultants
TOTALS
Shawn Kennedy ($950/hour)
 $           93,385.00 
 $      145,825.00 
 $                        91,390.00 
 $                          11,400.00 
 $      453,245.00 
 $                75,430.00 
 $  123,690.00 
 $               38,665.00 
 $  177,555.00 
 $  10,830.00 
1,221,415.00
$     
Bret Hembd ($825/hour)
 $           57,172.50 
 $        19,717.50 
 $                        14,107.50 
 $                                       -   
 $        67,072.50 
 $                  2,062.50 
 $    32,505.00 
 $               16,252.50 
 $    31,102.50 
 $    8,167.50 
248,160.00
$        
Nicomedes Herrera ($975/hour)
 $           68,055.00 
 $        33,540.00 
 $                        18,330.00 
 $                                       -   
 $        39,487.50 
 $                  3,510.00 
 $    42,120.00 
 $               21,742.50 
 $      8,385.00 
 $  15,990.00 
251,160.00
$        
Andrew Purdy ($950/hour)
 $           18,715.00 
 $          9,405.00 
 $                                     -   
 $                                       -   
 $        20,520.00 
 $                             -   
 $                 -    $                 3,420.00 
 $      3,800.00 
 $       665.00 
56,525.00
$          
Laura Seidl ($825/hour)
 $           14,932.50 
 $                     -   
 $                                     -   
 $                                       -   
 $          3,795.00 
 $                  4,042.50 
 $    10,725.00 
 $                           -   
 $         577.50 
 $               -   
34,072.50
$          
TOTALS
 $         252,260.00 
 $      208,487.50 
 $                      123,827.50 
 $                          11,400.00 
 $      584,120.00 
 $                85,045.00 
 $  209,040.00 
 $               80,080.00 
 $  221,420.00 
 $  35,652.50 
1,811,332.50
$  
In re Plaid Inc. Privacy Litigation
CATEGORY TIME REPORT 
Reporting Period: Inception - January 25, 2022
HERRERA KENNEDY LLP
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 25 of 68

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT B 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 26 of 68

4089-0001
TOTALS
Name
1
2
3
4
6
7
8
12
13
14
Cur. Hrs
Cum. Hrs
Rate
Cur. Lod
Cum. Lod
MICHAEL SOBOL
1.30
3.40
1.90
0
10.50
3.40
13.80
13.90
0.50
6.40
55.10
55.10
1,025.00
56,477.50
56,477.50
ARIANA DELUCCHI
0
32.60
0.70
0
24.90
1.00
12.30
69.10
0
0.50
141.10
141.10
395.00
55,734.50
55,734.50
DANNA ELMASRY
0
0
0
0
7.40
0
12.00
2.40
6.80
0
28.60
28.60
370.00
10,582.00
10,582.00
MELISSA GARDNER
31.00
45.00
137.00
5.20
228.10
64.20
184.10
90.50
53.80
22.50
861.40
861.40
610.00
525,454.00
525,454.00
RACHEL GEMAN
37.90
22.40
21.00
6.20
91.50
60.20
175.50
35.20
6.50
10.00
466.40
466.40
850.00
396,440.00
396,440.00
RHEA GHOSH
3.20
0.70
65.40
4.20
126.50
17.00
105.40
13.70
9.00
5.50
350.60
350.60
465.00
163,029.00
163,029.00
MADELINE GOMEZ
12.70
15.10
0
0
38.30
0
0
9.30
18.90
2.70
97.00
97.00
465.00
45,105.00
45,105.00
NICHOLAS HARTMANN
0.80
0
0
0
15.00
9.20
20.70
0
0
0
45.70
45.70
535.00
24,449.50
24,449.50
MIKE SHEEN
0
0
0
0
26.90
0
2.10
5.90
0
0
34.90
34.90
555.00
19,369.50
19,369.50
TOTALS HOURS:
86.90
119.20
226.00
15.60
569.10
155.00
525.90
240.00
95.50
47.60
2,080.80
2,080.80
$1,296,641.00
$1,296,641.00
TOTAL LODESTAR
$60,279.00
$70,199.00
$134,055.00
$10,395.00
$339,838.50
$107,039.00
$346,170.50
$141,524.50
$54,345.00
$32,795.50
$1,296,641.00
1,236,362.00
$    
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
TASK CODES    From Inception to 01-25-22
PLAID FINANCIAL PRIVACY - General Matter
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 27 of 68

Task Code
Description
1
Lead Counsel Calls/Meetings
10
Trial Preparation
11
Trial
12
Case Management & Litigation Strategy
13
Legal Research
14
Experts/Consultants
15
Appeal
2
Investigations/Factual Research
3
Discovery (Draft/Respond/Meet & Confer)
4
Discovery (Document Review)
5
Discovery (Depositions)
6
Pleadings, Briefs, Motions
7
Court Appearances & Preparation
8
Settlement
9
Class Certification
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 28 of 68

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT C 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 29 of 68

Timekeeper      
Lead Counsel 
Calls / Meetings 
Investigations / 
Factual Research 
Discovery (Draft / Respond 
/ Meet & Confer)
Discovery 
(Document Review)
Pleadings, Briefs, 
Motions 
Court Appearances & 
Preparation 
Settlement
Case Management & 
Litigation Strategy
Legal Research 
Experts / 
Consultants
TOTALS
Warren Burns
0.00
0.00
0.00
0.00
0.00
0.00
0.00
49.50
0.00
0.00
49.50
Chris Cormier
10.20
118.20
175.90
11.20
59.20
51.90
300.40
166.00
81.40
0.00
974.40
Jacob Gower
1.90
2.10
7.20
0.00
34.30
0.00
0.00
7.20
0.00
0.00
52.70
Russ Herman
1.00
0.00
128.00
0.00
38.90
0.50
0.00
51.10
8.00
0.00
227.50
Brittney Johnson
15.60
1.50
31.20
0.00
0.00
0.00
3.00
117.50
0.00
0.00
168.80
Mark Anderson
0.00
0.00
0.80
0.00
1.80
0.00
0.00
87.30
10.40
0.00
100.30
Andrew Bynum
0.00
0.00
12.70
0.30
0.00
0.00
0.00
0.20
0.00
0.00
13.20
Julianna Gravois
0.00
0.00
0.50
0.00
1.80
0.00
0.00
12.10
0.00
0.00
14.40
TOTAL
28.70
121.80
356.30
11.50
136.00
52.40
303.40
490.90
99.80
0.00
1,600.80
In re Plaid Inc. Privacy Litigation
CATEGORY TIME REPORT 
Reporting Period: Inception - January 25, 2022
Burns Charest LLP
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 30 of 68

Burns Charest LLP
Timekeeper     
Rate
Lead Counsel Calls / 
Meetings 
Investigations / 
Factual Research 
Discovery (Draft / Respond 
/ Meet & Confer)
Discovery (Document 
Review)
Pleadings, Briefs, 
Motions 
Court Appearances & 
Preparation 
Settlement
Case Management & 
Litigation Strategy
Legal Research 
Experts / 
Consultants
TOTALS
Warren Burns
$1,050.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$51,975.00
$0.00
$0.00
$51,975.00
Chris Cormier
$950.00
$9,690.00
$112,290.00
$167,105.00
$10,640.00
$56,240.00
$49,305.00
$285,380.00
$157,700.00
$77,330.00
$0.00
$925,680.00
Jacob Gower
$500.00
$950.00
$1,050.00
$3,600.00
$0.00
$17,150.00
$0.00
$0.00
$3,600.00
$0.00
$0.00
$26,350.00
Russ Herman
$600.00
$600.00
$0.00
$76,800.00
$0.00
$23,340.00
$300.00
$0.00
$30,660.00
$4,800.00
$0.00
$136,500.00
Brittney Johnson $550.00
$8,580.00
$825.00
$17,160.00
$0.00
$0.00
$0.00
$1,650.00
$64,625.00
$0.00
$0.00
$92,840.00
Mark Anderson
$425.00
$0.00
$0.00
$340.00
$0.00
$765.00
$0.00
$0.00
$37,102.50
$4,420.00
$0.00
$42,627.50
Andrew Bynum
$425.00
$0.00
$0.00
$5,397.50
$127.50
$0.00
$0.00
$0.00
$85.00
$0.00
$0.00
$5,610.00
Julianna Gravois $325.00
$0.00
$0.00
$162.50
$0.00
$585.00
$0.00
$0.00
$3,932.50
$0.00
$0.00
$4,680.00
TOTAL
$19,820.00
$114,165.00
$270,565.00
$10,767.50
$98,080.00
$49,605.00
$287,030.00
$349,680.00
$86,550.00
$0.00 $1,286,262.50
In re Plaid Inc. Privacy Litigation
CATEGORY LODESTAR REPORT 
Reporting Period: Inception - January 25, 2022
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 31 of 68

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT D 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 32 of 68

Disbursement
Burns 
Charest
Herrera 
Kennedy
Lieff 
Cabraser
Nussbaum 
Law
Reinhardt 
Wendorf
Robins 
Kaplan
Spector 
Roseman
Tostrud 
Law
Glancy 
Prongay
Criden 
Love  PA
Hartley
Cumulative Totals
Electronic Research (Lexis/Westlaw/PACER)
$160.60
$14,612.41
$5,312.12
$303.02
$7.70
$300.19
$796.35
$310.00
$79.50
$10.20
$21,892.09
Court Costs - Filing Fees
$400.00
$620.00
$310.00
$310.00
$710.00
$1,240.00
$320.00
$620.00
$4,530.00
Federal Express/Overnight Delivery/Messengers
$40.00
$32.20
$72.20
Photocopies - In House
$323.80
$17.55
$128.25
$469.60
Photocopies - Outside
$5,504.60
$5,504.60
Air Travel 
$583.22
$583.22
Meals 
$18.43
$18.43
Deposition Costs
$82.58
$82.58
Service of Process Fees
$100.50
$100.50
Telephone / Fax
$253.34
$121.00
$374.34
Experts/Consultant Fees
$12,913.90
$8,166.60
$12,249.90
$33,330.40
Mediation Expenses
$14,750.10
$9,833.39
$14,750.10
$39,333.59
Misc. (Describe) Electronic Database
$8,820.00
$8,820.00
Misc. (Describe) Other Charges
$808.66
$808.66
TOTAL 
$27,843.03
$33,052.40
$48,857.80
$630.57
$317.70
$1,010.19
$2,036.35
$1,142.47
$399.50
$630.20
$0.00
$115,920.21
In re Plaid Inc. Privacy Litigation
ALL FIRM EXPENSE REPORT 
Firm Name: ALL FIRMS
Reporting Period: Inception - January 25, 2022
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 33 of 68

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EXHIBIT E 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 34 of 68

1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
26 
27 
28 
 
 
2333486.1  
 
DECLARATION OF CAROLINE ANDERSON ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 CAROLINE 
ANDERSON IN SUPPORT OF FINAL 
APPROVAL OF SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 35 of 68

1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
26 
27 
28 
 
 
2333486.1  
 
DECLARATION OF CAROLINE ANDERSON ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, Caroline Anderson, declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of final approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met in person with counsel on multiple occasions or communicated by phone and 
email to stay informed, including during the mediations and settlement negotiations.  I will 
continue to do so during this settlement approval process, as needed.  In addition, I have also: 
• helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
• reviewed and discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
• searched for and provided to counsel and preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, and my financial 
account(s). 
• gathered and provided information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 36 of 68

1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
26 
27 
28 
 
 
2333486.1  
- 2 - 
DECLARATION OF CAROLINE ANDERSON ISO 
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
• provided my counsel with my mobile device, which contains highly sensitive and 
important personal information.  I agreed to allow my device to be forensically 
imaged, and for certain data to be extracted and provided to Defendant, in order to 
support my claims and this litigation generally. 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in detail in the settlement agreement, offers a fair resolution of my claims against 
Defendant, and that implementing these changes now is preferable to continuing this litigation for 
a lengthy amount of time and and an uncertain and possibly negative outcome.  As reflected in 
Plaintiffs’ motion for final approval, counsel is available to address all questions about the 
settlement, including allocation of settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this 10th day of January, 2022, in Dunbarton, New Hampshire. 
 
 
By:  
 
 
 
 
 
 
 
Caroline Anderson 
 
 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 37 of 68

1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
26 
27 
28 
 
 
 
2333486.1  
 
DECLARATION OF JAMES COTTLE ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 JAMES COTTLE IN 
SUPPORT OF FINAL APPROVAL OF 
SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 


		

Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 38 of 68

1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
26 
27 
28 
 
 
2333486.1  
 
DECLARATION OF JAMES COTTLE ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, James Cottle, declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of final approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met in person with counsel on multiple occasions or communicated by phone and 
email to stay informed, including during the mediations and settlement negotiations.  I will 
continue to do so during this settlement approval process, as needed.  In addition, I have also: 
• helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
• reviewed and discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
• searched for and provided to counsel and preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, and my financial 
account(s). 
• gathered and provided information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  


		

Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 39 of 68

1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
26 
27 
28 
 
 
 
2333486.1  
- 2 - 
DECLARATION OF JAMES COTTLE ISO 
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
• provided my counsel with my mobile device, which contains highly sensitive and 
important personal information.  I agreed to allow my device to be forensically 
imaged, and for certain data to be extracted and provided to Defendant, in order to 
support my claims and this litigation generally. 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in detail in the settlement agreement, offers a fair resolution of my claims against 
Defendant, and that implementing these changes now is preferable to continuing this litigation for 
a lengthy amount of time and and an uncertain and possibly negative outcome.  As reflected in 
Plaintiffs’ motion for final approval, counsel is available to address all questions about the 
settlement, including allocation of settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this 21st day of January, 2022, in San Anselmo, California. 
 
 
By:  
 
 
 
 
 
 
 
James Cottle 
 
 


		


Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 40 of 68

Certificate Of Completion
Envelope Id: 43A39987415347E9A395D65F425DDC6A
Status: Completed
Subject: Please DocuSign: Plaid - Class Representative Declaration ISO Final Approval of Settlement (COT...
Source Envelope: 
Document Pages: 3
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James Cottle
AutoNav: Enabled
EnvelopeId Stamping: Enabled
Time Zone: (UTC-08:00) Pacific Time (US & Canada)
181 3rd St #225
San Rafael, CA  94901
james@holmesburrell.com
IP Address: 76.126.107.247 
Record Tracking
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Holder: James Cottle
             james@holmesburrell.com
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James Cottle
james@holmesburrell.com
Holmes Burrell Real Estate
Holmes Burrell Real Estate
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Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 41 of 68

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2333486.1  
 
DECLARATION OF DAVID EVANS ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 DAVID EVANS IN 
SUPPORT OF FINAL APPROVAL OF 
SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 45 of 68

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2333486.1  
 
DECLARATION OF DAVID EVANS ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, DAVID EVANS, declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of final approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met in person with counsel on multiple occasions or communicated by phone and 
email to stay informed, including during the mediations and settlement negotiations.  I will 
continue to do so during this settlement approval process, as needed.  In addition, I have also: 
 helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
 reviewed and discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
 searched for and provided to counsel and preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, and my financial 
account(s). 
 gathered and provided information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 46 of 68

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2333486.1  
- 2 - 
DECLARATION OF DAVID EVANS ISO 
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 offered to provide my counsel with my mobile device, which contains highly 
sensitive and important personal information.  I agreed to allow my device to be 
forensically imaged, and for certain data to be extracted and provided to 
Defendant, in order to support my claims and this litigation generally. 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in detail in the settlement agreement, offers a fair resolution of my claims against 
Defendant, and that implementing these changes now is preferable to continuing this litigation for 
a lengthy amount of time and and an uncertain and possibly negative outcome.  As reflected in 
Plaintiffs’ motion for final approval, counsel is available to address all questions about the 
settlement, including allocation of settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this _____ day of January, 2022, in __________, _______. 
 
 
 
By:  
 
 
 
 
 
 
 
David Evans 
 
 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 47 of 68

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2333486.1  
 
DECLARATION OF LOGAN MITCHELL ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 LOGAN MITCHELL 
IN SUPPORT OF FINAL APPROVAL OF 
SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 
DocuSign Envelope ID: AD9ADBA2-4741-44E6-9564-45226D979994
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 48 of 68

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2333486.1  
 
DECLARATION OF LOGAN MITCHELL ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, Logan Mitchell declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of final approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met with counsel on multiple occasions or communicated by phone and email to 
stay informed, including during the mediations and settlement negotiations.  I will continue to do 
so during this settlement approval process, as needed.  In addition, I have also: 
 helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
 reviewed and discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
 searched for and provided to counsel and preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, and my financial 
account(s). 
 gathered and provided information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  
DocuSign Envelope ID: AD9ADBA2-4741-44E6-9564-45226D979994
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 49 of 68

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2333486.1  
- 2 - 
DECLARATION OF LOGAN MITCHELL ISO 
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 provided my counsel with my mobile device, which contains highly sensitive and 
important personal information.  I agreed to allow my device to be forensically 
imaged, and for certain data to be extracted and provided to Defendant, in order to 
support my claims and this litigation generally. 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in detail in the settlement agreement, offers a fair resolution of my claims against 
Defendant, and that implementing these changes now is preferable to continuing this litigation for 
a lengthy amount of time and and an uncertain and possibly negative outcome.  As reflected in 
Plaintiffs’ motion for final approval, counsel is available to address all questions about the 
settlement, including allocation of settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this ___th day of January, 2022, in San Diego, California. 
 
 
By:                              
 
           Logan Mitchell 
 
 
 
 
DocuSign Envelope ID: AD9ADBA2-4741-44E6-9564-45226D979994
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Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 50 of 68

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2333486.1  
 
DECLARATION OF ALEXIS MULLEN ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 ALEXIS MULLEN IN 
SUPPORT OF FINAL APPROVAL OF 
SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 51 of 68

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2333486.1  
 
DECLARATION OF ALEXIS MULLEN ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, ALEXIS MULLEN declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of final approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met in person with counsel on multiple occasions or communicated by phone and 
email to stay informed, including during the mediations and settlement negotiations.  I will 
continue to do so during this settlement approval process, as needed.  In addition, I have also: 
• helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
• reviewed and discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
• searched for and provided to counsel and preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, and my financial 
account(s). 
• gathered and provided information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 52 of 68

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2333486.1  
- 2 - 
DECLARATION OF ALEXIS MULLEN ISO 
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
• provided my counsel with my mobile device, which contains highly sensitive and 
important personal information.  I agreed to allow my device to be forensically 
imaged, and for certain data to be extracted and provided to Defendant, in order to 
support my claims and this litigation generally. 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in detail in the settlement agreement, offers a fair resolution of my claims against 
Defendant, and that implementing these changes now is preferable to continuing this litigation for 
a lengthy amount of time and and an uncertain and possibly negative outcome.  As reflected in 
Plaintiffs’ motion for final approval, counsel is available to address all questions about the 
settlement, including allocation of settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this _____ day of January, 2022, in __________, _______. 
 
 
By:  
 
 
 
 
 
 
 
ALEXIS MULLEN 
 
 
10
PA
Philadelphia
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 53 of 68

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2333486.1  
 
DECLARATION OF JORDAN SACKS ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 JORDAN SACKS IN 
SUPPORT OF FINAL APPROVAL OF 
SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 54 of 68

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2333486.1  
 
DECLARATION OF JORDAN SACKS ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, JORDAN SACKS declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of final approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met in person with counsel on multiple occasions or communicated by phone and 
email to stay informed, including during the mediations and settlement negotiations.  I will 
continue to do so during this settlement approval process, as needed.  In addition, I have also: 
x helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
x reviewed and discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
x searched for and provided to counsel and preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, and my financial 
account(s). 
x gathered and provided information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 55 of 68

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2333486.1  
- 2 - 
DECLARATION OF JORDAN SACKS ISO 
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
x provided my counsel with my mobile device, which contains highly sensitive and 
important personal information.  I agreed to allow my device to be forensically 
imaged, and for certain data to be extracted and provided to Defendant, in order to 
support my claims and this litigation generally. 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in detail in the settlement agreement, offers a fair resolution of my claims against 
Defendant, and that implementing these changes now is preferable to continuing this litigation for 
a lengthy amount of time and and an uncertain and possibly negative outcome.  As reflected in 
Plaintiffs’ motion for final approval, counsel is available to address all questions about the 
settlement, including allocation of settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this _____ day of January, 2022, in __________, _______. 
 
 
By:  
 
 
 
 
 
 
 
JORDAN SACKS 
 
 
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 56 of 68
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Arlington, VA

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2333486.1  
 
DECLARATION OF FREDERICK SCHOENEMAN  ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 FREDERICK 
SCHOENEMAN IN SUPPORT OF FINAL 
APPROVAL OF SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 
DocuSign Envelope ID: 4B46EA56-731E-4B6F-B2DB-4EE3FB842D68
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 57 of 68

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2333486.1  
 
DECLARATION OF FREDERICK SCHOENEMAN  ISO  
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, Frederick Schoeneman, declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of final approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met in person with counsel on multiple occasions or communicated by phone and 
email to stay informed, including during the mediations and settlement negotiations.  I will 
continue to do so during this settlement approval process, as needed.  In addition, I have also: 
 helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
 reviewed and discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
 searched for and provided to counsel and preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, and my financial 
account(s). 
 gathered and provided information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  
DocuSign Envelope ID: 4B46EA56-731E-4B6F-B2DB-4EE3FB842D68
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 58 of 68

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2333486.1  
- 2 - 
DECLARATION OF [NAME] ISO 
FINAL APPROVAL OF SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 provided my counsel with my mobile device, which contains highly sensitive and 
important personal information.  I agreed to allow my device to be forensically 
imaged, and for certain data to be extracted and provided to Defendant, in order to 
support my claims and this litigation generally. 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in detail in the settlement agreement, offers a fair resolution of my claims against 
Defendant, and that implementing these changes now is preferable to continuing this litigation for 
a lengthy amount of time and and an uncertain and possibly negative outcome.  As reflected in 
Plaintiffs’ motion for final approval, counsel is available to address all questions about the 
settlement, including allocation of settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this 2st day of January, 2022, in __________, _______. 
 
 
By:  
 
 
 
 
 
 
 
FREDERICK SCHOENEMAN 
 
 
DocuSign Envelope ID: 4B46EA56-731E-4B6F-B2DB-4EE3FB842D68
1/21/2022
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 59 of 68

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2346352.1  
 
DECLARATION OF GABRIEL SOTELO ISO COURT  
APPROVAL OF THE SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 GABRIEL SOTELO  
IN SUPPORT OF COURT APPROVAL OF 
THE SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 
DocuSign Envelope ID: 8B6D8361-D8EB-4C9B-991C-0C2A3D6FFA45
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 60 of 68

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2346352.1  
 
DECLARATION OF GABRIEL SOTELO ISO COURT  
APPROVAL OF THE SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, Gabriel Sotelo declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of Court approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met in person with counsel on multiple occasions or communicated by phone and 
email to stay informed, including during the mediations and settlement negotiations.  I will 
continue to do so during this settlement approval process, as needed.  In addition, I have also: 
 helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
 reviewed or discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
 searched for and provided to counsel or preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, or my financial 
account(s). 
 gathered and provided  information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  
DocuSign Envelope ID: 8B6D8361-D8EB-4C9B-991C-0C2A3D6FFA45
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 61 of 68

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2346352.1  
- 2 - 
DECLARATION OF GABRIEL SOTELO ISO COURT  
APPROVAL OF THE SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in close detail in the settlement agreement, offers a fair resolution of my claims 
against Defendant, and that implementing these changes now is preferable to carrying on for 
uncertain and possibly low classwide payments.  As reflected in Plaintiffs’ motion for final 
approval, counsel is available to address all questions about the settlement, including allocation of 
settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this 24th day of January, 2022, in Portland, Oregon. 
 
 
By:  
 
 
 
 
 
 
 
Gabriel Sotelo   
 
 
DocuSign Envelope ID: 8B6D8361-D8EB-4C9B-991C-0C2A3D6FFA45
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 62 of 68

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2346354.1  
 
DECLARATION OF JEFFREY UMALI ISO COURT  
APPROVAL OF THE SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
 
 
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 JEFFREY UMALI IN 
SUPPORT OF COURT APPROVAL OF 
THE SETTLEMENT 
 
 
THIS DOCUMENT RELATES TO: 
ALL ACTIONS 
DocuSign Envelope ID: 21E70D82-0BA1-4581-AD26-3B2A0DBCA589
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 63 of 68

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2346354.1  
 
DECLARATION OF JEFFREY UMALI ISO COURT  
APPROVAL OF THE SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
I, Jeffrey Umali declare as follows: 
1. 
I am one of the class representatives appointed in this case. 
2. 
I submit this declaration in support of Court approval of the settlement.  I have 
personal knowledge of the facts stated herein.  If called to testify to the contents of this 
declaration, I could and would competently do so. 
3. 
I voluntarily undertook the burdens and risks associated with this lawsuit to try to 
stop Defendant’s unauthorized collection and use of my private financial information as well as 
that of other class members. 
4. 
I have participated actively in this lawsuit.  I have followed the status and progress 
of the case and met in person with counsel or communicated by phone and email to stay 
informed, including during the mediations and settlement negotiations.  I will continue to do so 
during this settlement approval process, as needed.  In addition, I have also: 
 helped counsel draft the amended complaint by describing to them my story and 
relevant facts and events.  As part of that process, I reviewed and provided 
documents and information, including from my mobile device, applications I use, 
and my financial account(s).  
 reviewed or discussed with my counsel numerous other documents related to this 
case, including this Court’s motion to dismiss order, discovery request responses, 
the preliminary approval briefing, and the settlement. 
 searched for and provided to counsel or preserved any documents that were 
pertinent to the case, understanding that Defendant would receive copies of 
documents to which they were entitled, possibly even private documents, 
including some related to my mobile device, applications I use, or my financial 
account(s). 
 gathered and provided  information relevant to the case needed to respond to 
numerous interrogatories served by Defendant, and reviewed the responses to 
those interrogatories for accuracy.  
DocuSign Envelope ID: 21E70D82-0BA1-4581-AD26-3B2A0DBCA589
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 64 of 68

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2346354.1  
- 2 - 
DECLARATION OF JEFFREY UMALI  ISO COURT  
APPROVAL OF THE SETTLEMENT 
CASE NO. 4:20-CV-03056-DMR 
 
5. 
I believe that the injunctive and monetary relief provided by the settlement, which 
is described in close detail in the settlement agreement, offers a fair resolution of my claims 
against Defendant, and that implementing these changes now is preferable to carrying on for 
uncertain and possibly low classwide payments.  As reflected in Plaintiffs’ motion for final 
approval, counsel is available to address all questions about the settlement, including allocation of 
settlement funds.   
6. 
I have never been promised any compensation for performing my duties as a 
plaintiff and class representative, including any service award, and am aware of no interest of 
mine in this litigation that conflicts with the interests of other class members.  I understand, 
however, that Class Counsel intends to request that the Court award me $5,000 for my time and 
efforts on behalf of the settlement class.   
I declare under penalty of perjury that the foregoing is true and correct.   
Executed this _____th day of January, 2022, in Spring Valley, California. 
 
 
By:  
 
 
 
 
 
 
 
Jeffrey Umali 
 
 
DocuSign Envelope ID: 21E70D82-0BA1-4581-AD26-3B2A0DBCA589
13
Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 65 of 68

Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 66 of 68

Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 67 of 68

Case 4:20-cv-03056-DMR   Document 157-1   Filed 01/28/22   Page 68 of 68

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