Exhibit 1 - Cormier Declaration — Plaid Privacy (Dkt. 182.1)

Record facts

U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 182-1 · 2022-05-19 · Docket on CourtListener

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EXHIBIT 1 
Case 4:20-cv-03056-DMR     Document 182-1     Filed 05/19/22     Page 1 of 7

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2417249.1  
  
CORMIER DECL. ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR 
 
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 
 
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 
Laura E. Seidl (SBN 269891) 
lseidl@herrerakennedy.com 
1300 Clay Street, Suite 600 
Oakland, CA 94612 
Tel: (510) 422-4700 
Fax: (855) 969-2050 
 
Co-Lead Class Counsel 
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 
 
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 
 
 
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 CHRISTOPHER J. 
CORMIER IN SUPPORT OF 
PLAINTIFFS’ MOTION FOR 
ATTORNEYS’ FEES, REIMBURSEMENT 
OF EXPENSES, AND PLAINTIFF 
SERVICE AWARDS, AND IN RESPONSE 
TO COURT’S ORDER (DKT. 177) 
 
 
THIS DOCUMENT RELATES TO:  
ALL ACTIONS 
 
Case 4:20-cv-03056-DMR     Document 182-1     Filed 05/19/22     Page 2 of 7

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2417249.1  
  
CORMIER DECL. ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR 
 
I, Christopher J. Cormier, hereby declare as follows: 
1. 
I am a member in good standing of the District of Columbia and Colorado Bars, 
and am admitted pro hac vice in this matter to practice in the United Stated District Court for the 
Northern District of California.  I am a partner at the law firm of Burns Charest LLP (“Burns 
Charest”), which was appointed Co-Lead Interim Class Counsel on July 29, 2020 (Dkt. 57) and 
Co-Lead Class Counsel on November 19, 2021 (Dkt. 153).  I am over 21 years of age and am not 
a party to this action.  I make this declaration based on my own personal knowledge.  If called 
upon to testify, I could and would testify competently to the truth of the matters stated herein.  
2. 
I submit this declaration in further support of Plaintiffs’ Motion for Attorneys’ 
Fees, Reimbursement of Expenses, and Plaintiff Service Awards (Dkt. 157) and specifically in 
response to the Court’s request for certain supplemental information at the Final Approval 
Hearing on May 12, 2022 (see Dkts. 177, 180).  The Court directed Burns Charest to submit 
support for the hourly rates requested for “all timekeepers other than Chris Cormier and Warren 
Burns.” Dkt. 177 at 1. This support for each requested timekeeper—Russ Herman, Brittney 
Johnson, Jacob Gower, Mark Anderson, Andrew Bynum and Juliana Gravois—follows. 
3. 
Russ Herman was an Associate at the firm until May 2021. Before joining the firm 
in 2019, he was an associate at Lynn Pinker Cox & Hurst, LLP and Baker Botts LLP, and he 
served as a law clerk for the Honorable George Kazen of the United States District Court for the 
Southern District of Texas. He received his JD from Harvard Law School in 2012 and graduated 
with a BA from Dartmouth College in 2006. Mr. Herman’s hourly rate was submitted and 
approved in connection with class plaintiffs’ attorneys’ fees request in In re Broiler Chicken 
Grower Antitrust Litigation (No. II), Case No. 6:20-MD-02977-RJS-CMR (E.D. Ok. Feb. 18, 
2022) (see Dkts. 488-13 and 531). 
4. 
Mr. Herman joined the Burns Charest team on this case in April 2020, shortly 
before the initial complaint was filed. He performed various tasks under my direction and 
supervision on this case until his departure in May 2021, including:  conducting legal research 
and analysis regarding claims asserted in the consolidated amended complaint; drafting sections 
of the consolidated amended complaint; conducting legal research and drafting parts of Plaintiffs’ 
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2417249.1  
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CORMIER DECL. ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR  
 
responses to Defendant’s motions to dismiss the consolidated amended complaint, to stay, and 
other briefs; drafting Plaintiffs’ initial disclosures; meeting and conferring, conducting legal 
research, and drafting related memoranda and letters regarding the parties’ ESI protocol and 
Defendant’s responses to Plaintiff’s discovery requests; working with Plaintiff’s ESI vendor and 
with the named Plaintiffs and their respective counsel on Plaintiffs’ electronic document 
retention, collection and production efforts; and drafting responses and objections to Defendant’s 
discovery requests to Plaintiffs.  In total, Mr. Herman recorded 227.50 hours of work, at a rate of 
$600 per hour, for a total lodestar of $136,500.00.  See Dkt. 157-1 Ex. C.   
5. 
Brittney Johnson was an Associate at the firm until December 2021. Before 
joining the firm in 2021, she was an associate at, among other firms, Faegre Drinker Biddle & 
Reath LLP and Bowman and Brooke LLP. She received her JD from Baylor University Law 
School in 2012 and graduated with a BS from Texas A&M University in 2008. Ms. Johnson’s 
hourly rate was submitted and approved in connection with class plaintiffs’ attorneys’ fees 
request in In re Broiler Chicken Grower Antitrust Litigation (No. II), Case No. 6:20-MD-02977-
RJS-CMR (E.D. Ok. Feb. 18, 2022) (see Dkts. 488-13 and 531). 
6. 
Ms. Johnson joined the Burns Charest team on this case in May 2021.  She 
performed various tasks under my direction and supervision on this case until her departure in 
December 2021, including:  working with Plaintiff’s ESI vendor and with the named Plaintiffs 
and their respective counsel on Plaintiffs’ electronic document retention, collection and 
production efforts; drafting responses and objections to and meeting and conferring with 
Defendants concerning Defendant’s discovery requests to Plaintiffs; assisting in the preparation 
of Plaintiff’s motion for preliminary approval of the proposed class settlement and supporting 
papers. In total, Ms. Johnson recorded 168.80 hours of work, at a rate of $550 per hour, for a total 
lodestar of $92,840.00.  See Dkt. 157-1 Ex. C.   
7. 
Jacob Gower was an Associate at the firm until late 2021. Before joining the firm 
in 2016, he was an associate at Slattery, Marino & Roberts PLC, and he served as a law clerk for 
the Honorable Magistrate Judge Kathleen Kay of the United States District Court for the Western 
District of Louisiana. He received his JD from Louisiana State University Law School in 2012 
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CORMIER DECL. ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR  
 
(graduating magna cum laude and Order of the Coif) and obtained a BA from Louisiana State 
University in 2009. Mr. Gower served on the co-lead class counsel team in In re EpiPen 
(Epinephrine Injection, USP) Marketing, Sales Practices and Antitrust Litigation, where the court 
awarded the requested attorney fees representing a specified multiplier of the hourly rates of the 
lawyers and paralegals of Burns Charest LLP and the other co-lead firms in connection with the 
Pfizer Defendants settlement. See 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) and Dkt. 2435-2 at ¶¶ 63-65. 
8. 
Mr. Gower joined the Burns Charest team on this case in April 2020, shortly 
before the initial complaint was filed. He performed various tasks under my direction and 
supervision on this case until his departure in December 2021, including:  conducting legal 
research and analysis regarding claims asserted in the consolidated amended complaint; drafting 
sections of the consolidated amended complaint; conducting legal research and drafting parts of 
Plaintiffs’ responses to Defendant’s motions to dismiss the consolidated amended complaint, to 
stay, and other briefs; and assisting in drafting Plaintiffs’ initial disclosures.  In total, Mr. Gower 
recorded 52.70 hours of work, at a rate of $500 per hour, for a total lodestar of $26,350.00.  See 
Dkt. 157-1 Ex. C.   
9. 
Mark Anderson has been a senior Paralegal at the firm since its founding in 2015. 
Mr. Anderson’s hourly rate was submitted and approved in connection with class plaintiffs’ 
attorneys’ fees requests in In re Broiler Chicken Grower Antitrust Litigation (No. II), Case No. 
6:20-MD-02977-RJS-CMR (E.D. Ok. Feb. 18, 2022) (see Dkts. 488-13 and 531), and Bhatia v. 
3M Co., Case No. 16-cv-01304-DWF-DTS (D. Minn. Sept. 11, 2019) (see Dkts. 149-1 (Ex. B) 
and 156). 
10. 
Mr. Anderson joined the Burns Charest team on this case in May 2020.  He has 
performed various tasks under my direction and supervision on this case, including:  conducting 
discrete fact research; assisting with and preparing documents for filing and service; working with 
counsel and vendors regarding document productions and document housing; maintaining and 
updating attorney and client contact lists; maintaining and updating the case calendar containing 
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CORMIER DECL. ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR  
 
all internal and external deadlines; and maintaining and updating class counsel’s time and 
expense report submissions and related correspondence.  In total, Mr. Anderson recorded 100.30 
hours of work, at a rate of $425 per hour, for a total lodestar of $42,627.50.  See Dkt. 157-1 Ex. 
C.   
11. 
Andrew Bynum has been a senior Paralegal at the firm since its founding in 2015. 
Mr. Bynum’s hourly rate was submitted and approved in connection with class plaintiffs’ 
attorneys’ fees requests in In re Broiler Chicken Grower Antitrust Litigation (No. II), Case No. 
6:20-MD-02977-RJS-CMR (E.D. Ok. Feb. 18, 2022) (see Dkts. 488-13 and 531), Bhatia v. 3M 
Co., Case No. 16-cv-01304-DWF-DTS (D. Minn. Sept. 11, 2019) (see Dkts. 149-1 (Ex. B) and 
156), and Scola v. Facebook, Inc., Civ. No. 18CIV05135 (Cal. Sup. Ct., San Mateo County, July 
14, 2021) (see July 14, 2021 Order Granting Plaintiffs’ Renewed and Unopposed Mot. for 
Attorneys’ Fees, Reimbursement of Costs, and Service Awards and Oct. 9, 2020 Daniel Charest 
Decl. in Support of Mot. for Attorneys’ Fees, Reimbursement of Costs, and Service Awards; 
accessible via https://www.sanmateocourt.org/online_services/odyssey_portals.php). 
12. 
Mr. Bynum joined the Burns Charest team on this case in April 2021.  He has 
performed tasks under my direction and supervision on this case primarily focused on Plaintiffs’ 
ESI, including:  assisting with the selection, engagement and scope of work of Plaintiff’s ESI 
vendor and working with counsel and the ESI vendor on the preservation, collection and 
production of named Plaintiffs’ ESI.  In total, Mr. Bynum recorded 13.20 hours of work, at a rate 
of $425 per hour, for a total lodestar of $5,610.00.  See Dkt. 157-1 Ex. C.   
13. 
Juliana Gravois has been a Paralegal at the firm since early 2019. Ms. Gravois’ 
hourly rate was submitted and approved in connection with class plaintiffs’ attorneys’ fees 
request in Scola v. Facebook, Inc., Civ. No. 18CIV05135 (Cal. Sup. Ct., San Mateo County July 
14, 2021) (see July 14, 2021 Order Granting Plaintiffs’ Renewed and Unopposed Mot. for 
Attorneys’ Fees, Reimbursement of Costs, and Service Awards and Oct. 9, 2020 Daniel Charest 
Decl. in Support of Mot. for Attorneys’ Fees, Reimbursement of Costs, and Service Awards; 
accessible via https://www.sanmateocourt.org/online_services/odyssey_portals.php). 
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2417249.1  
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CORMIER DECL. ISO MOT. FOR ATTORNEYS’ FEES, 
EXPENSES, AND SERVICE AWARDS 
CASE NO. 4:20-CV-03056-DMR  
 
14. 
Ms. Gravois joined the Burns Charest team on this case in June 2020.  She has 
performed tasks under my direction and supervision on this case, including:  assisting with and 
preparing documents for filing and service; and circulating filings and correspondence to counsel.  
In total, Ms. Gravois recorded 14.40 hours of work, at a rate of $325 per hour, for a total lodestar 
of $4,680.00.  See Dkt. 157-1 Ex. C.   
15. 
Burns Charest personnel have continued to perform work on the case since 
January 25, 2022 (i.e., time not covered in Plaintiffs’ fee submission). This time primarily has 
been spent on coordinating with the settlement fund’s escrow account agent, coordinating with 
the notice and settlement administrator, responding to Class Member inquiries, and preparing for 
and attending the Final Approval Hearing. Furthermore, the firm will continue to perform work 
on the case not covered in Plaintiffs’ fee submission as needed until the case’s conclusion. 
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 19th day of May, 2022, in Washington, D.C. 
 
     /s/ Christopher J. Cormier 
 
          Christopher J. Cormier 
 
Case 4:20-cv-03056-DMR     Document 182-1     Filed 05/19/22     Page 7 of 7

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