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I KEITH A. JACOBY,Bar No. 150233 superior court of California
. ANDREW M.SPURCHISE,Bar No. 245998 County of Los Angeles
2 SOPHIA BEHNIA,Bar No. 289318
RACHAEL LAVI, Bar No. 294443 JAN 2 3 2018
3 LITTLER MENDELSON,P.C.
2049 Century Park East, 5th Floor Sherri R,Larter,
"ecutive Officer/Clerk
4 Los Angeles, California 90067.3107
Telephone: 310.553.0308; Fax No.: 310.553.5583 ,Deputy
Rita Na—zaryan
5
THEODORE J. BOUTROUS,Jr., Bar No. 132099
6 THEANE D. EVANGELIS,Bar No. 243570
DHANANJAY S. MANTHRIPRAGADA,Bar No. 254433
7 GIBSON,DUNN & CRUTCHER LLP
333 South Grand Avenue
8 Los Angeles, California 90071-3197
Telephone: 213.229.7000; Fax No.: 213.229.7520 1 1,
9 IV,
JOSHUA S. LIPSHUTZ, Bar No. 242557
10 KEVIN J. RING-DOWELL,Bar No. 278289
GIBSON,DUNN & CRUTCHER.LLP
II 555 Mission Street, Suite 3000
San Francisco, California 94105.0921
12 Telephone: 415.393.8200; Fax No.: 415.393.8306

13 Attorneys for Defendants

F14
UBER TECHNOLOGIES,INC. and RASIER-CA,LLC
14
SUPERIOR COURT OF THE STATE OF CALIFORNIA
15
COUNTY OF LOS ANGELES
16
STEVEN PRICE, an individual; Case No. BC554512
17 individually and on behalf of all others
similarly situated, ASSIGNED FOR ALL PURPOSES TO
18 HON.LISA HART COLE — DEPT. 307
Plaintiff,
19 NOTICE OF ORDER GRANTING JOINT
V. MOTION FOR APPROVAL OF PAGA
20 SETTLEMENT AND GRANTING
UBER TECHNOLOGIES,INC., a PLAINTIFFS' REQUEST FOR DISMISSAL
21 Delaware Corporation, RASIER-CA,LLC, OF ACTION
a Delaware Limited Liability Company,
~ 22 and DOES 2 through 100, inclusive, Date: January 16, 2018
Time: 2:00 p.m.
23 Defendants. Dept.: 307

24 Complaint Filed: August 12, 2014

Doe Amendment'Filed: April 8, 2015
25 Trial Date: None set

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6-ji
LITTLER MENDELSON,P.C.
2049 Century Park East
Case No. BC554512
L."111— C~
90067 NOTICE OF ORDER
310.553.0308
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I PLEASE TAKE NOTICE that on January 16, 2018 at 2:00 p.m., the Court held a

2 hearing on the parties Joint Motion for Approval ofPAGA Settlement in the above captioned matter.

3 The Court granted the Joint Motion. On January 18, 2018, the Court entered an Order Granting Joint

4 Motion For Approval Of PAGA Settlement And Granting Plaintiffs' Request For Dismissal Of

5 Action. A true and correct copy of the Court's January 18, 2018 Order is attached hereto as Exhibit

6 A.

7 Dated: January 22, 2018

8

9
TH A q~':'JACOBY
10 A DREW M.SPURCHISE'
SOPHIA BEHNIA
II RACHAEL LAVI
LITTLER MENDELSON,P.C.
12 Attorneys for Defendants
UBER TECHNOLOGIES,INC. and RASIER-
13 CA,LLC
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15

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Firmwide:152425654.1 073208.1032
17

18

19

20

21

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25

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LITTLER MENDELSON,P.C.
2049 Cenhiry Park East
5th A.,
Case No. BC554512
Los
Angeles,
90067
CA NOTICE OF ORDER
310.553.0308
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EXHIBIT A
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EXHIBIT A
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E-Served: Jan 19 2018 11:45AM PST Via Case Anywhere

I 1-OS)'Frl )WURT
2
'AN 18 2018
. -- /;- ILI (%.~j.iv-u-jix-nt\
By A, AbvaAcg D"
3 WANCY NAVARRO

9 SUPERIOR COURT OF CALIFORNIA

10 COUNTY OF LOS ANGELES

11

12 STEVEN PRICE, an individual; individually Case No.: BC554512

and on behalf ofall others similarly situated, Related to BC585704, BC59135 1, BC599027
13

Plaintiff,
14 RDER GRANTING JOINT MOTION FOR
PPROVAL OF PAGA SETTLEMENT AND
V.
15 GRANTING PLAINTIFFS' REQUEST FOR
ISMISSAL OF ACTION
16 UBER TECHNOLOGIES,INC., a Delaware
corporation, and DOES I through 100,
17 inclusive, Date: January 16, 2018
Time: 2:00 p.m.
18 Defendants. Dept.: 307

19

20

21 1. BACKGROUND
22
Plaintiff Steven Price filed this action against Defendant Uber Technologies, Inc. on
23
August 12, 2014. The pleading sets forth ten claims on behalf ofthe class and a representative
24
cause of action under the Labor Code Private Attorneys General Act of2004(PAGA), Labor
25

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Code § 2698, et. seq. Plaintiff filed an amendment adding Defendant Raiser-CA,LLC,as Doe I

in April, 2015. Uber and Raiser filed answers.

It is alleged Uber provides technology linking drivers and passengers, as well as other

services and that Uber has a uniform policy of willfully misclassifying drivers as independent

contractors when,in fact, drivers are Uber's employees.(Complaint,12.)

In February, 2017,the parties filed a joint stipulation for settlement of the PAGA claim.

Concurrently, the parties submitted a stipulation to allow the filing ofa First Amended

Complaint and Price filed a request for dismissal ofthe class claims. Hearings on the request for

approval ofthe PAGA settlement were held on March 10, 2017 and June 30,2017,after which

supplemental briefing was permitted, the last of which was received August 15, 2017.

The Court declined to approve the prior PAGA settlement agreement for two primary

reasons. First, the release was overly broad as it purported to release PAGA claims related to any

possible Labor Code violation, whether or not alleged in the Complaint. Second, the Court was

concerned about the fairness of providing incentive payments to the representative class member

(Price) and to the proposed additional named class member(Aly). Thus, on September 14, 2017,

the Court issued an order denying approval, without prejudice to a renewed motion putting forth

a settlement with a narrower release and without incentive payments to Price or Aly.

The parties revised their proposed settlement agreement. The two issues identified in the

September 14, 2017 Order are addressed in the revised settlement. On November 21, 2017 the

parties submitted a stipulation seeking approval of the settlement. Same was rejected. The

parties were instructed to file a noticed motion.

On December 21, 2017 a joint motion seeking to approve settlement ofthe PAGA claim

and dismiss the class claims was filed. The Labor and Workforce Redevelopment Agency

("LWDA")was notified of the revised settlement pursuant to statute and did not object thereto.

Counsel for plaintiffs in 0*Connor ei. al. v. Uber Technologies Inc., Case No. 13-cv-03826-
!4:1
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EMC("O'Connor") pending in the United States District Court for the Northern District of

California and counsel for plaintiffs in Del Rio v Uber Techs, Inc., No. 3:15-cv-03667-EMC(Del

Rio), also pending in the Northern District, filed objections.

Oral argument was conducted January 16, 2018, at which time, objectors were heard. The

settlement was orally approved at that time, as was the request to dismiss the class claims.

As discussed at oral argument,and to complete the record, this order sets forth the

Court's analysis ofthe issues presented. Familiarity with the Court's prior orders is assumed.

The findings, conclusions and orders from the Court's September 14, 2017 Order are

incorporated herein to the extent possible, except as to amendments to the settlement agreement.

11. DISCUSSION

A.The Claims Alleged

The gravamen of this litigation is the contention that Defendant misclassified its drivers

as independent contractors rather than employees. The proposed First Amended Complaint

contains the following causes of action:

1. Unlawful misclassification —Labor Code §226.8

2. Failure to pay minimum wage — Labor Code §§ 1182.12, 1194, 1194.2, 1197, 1197.1

3. Failure to Oay overtime compensation — Labor Code §§ H 94 and 1198

4. Failure to pay for missed meal periods — Labor Code §§ 226.7 and 512

5. Failure to pay for missed rest periods — Labor Code § 226.7

6. Failure to pay for reporting time — IWC Wage Order No.9-2001, §5

7. Failure to reimburse employee expenses — Labor Code §2802

8. Failure to keep accurate employment records — Labor Code §1174

9. Failure to provide accurate wage statements — Labor Code §226

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1 10. Unlawful business practices- B&P Code § 17200 et seq.(Minimum wages, overtime,

2 missed meal and rest periods, taking of employee gratuities(Labor Code §35 1), reporting

3 time, reimbursement, employee records, wage statements)

4 11. The PAGA claim - Labor Code §§ 2699(a)and/or (f)(Based on alleged violations of

5 Labor Code §§ 226, 226.7, 351, 353,432.5,450,510,512,551,552, 1174, 1194, 1197,

6 1197.1, 1198, 1199, and/or 2802).[Amended allegation in 1142,emphasis added. Uber

has violated and continues to violate Labor Code §§ 226, 226.3, 226.7, 351, 353,354,

8 432.5,450, 510, 512,551,552,558, 1174, 1174.5, 1194, 1197, 1197.1, 1198, 1199, 2753,

9 and/or 2802.]

10

11 B. Terms of the Proposed PAGA Settlement

12
A copy of the Amended Settlement Agreement is attached to the Memorandum of Points
13
and Authorities filed December 21, 2017. it contains the following essential terms:
14

is Driver means,"any individual who consented to a background check as part ofthe

16 sign-up process to use Uber software application and/or used the Uber software

17 application to generate leads in California at any time from July 8, 2013 up to and

18 including January 29,2017."(IIA)

19 PAGA Settlement Group Members means,"any and all Drivers who consented to a

20 background check as part of the sign-up process to use the Uber software application

21 and/or used the Uber software application to generate leads in California at any time

22 from July 8, 2013 up to and including January 29,2017."(Il.r)

23 Settlement Sum means the total gross settlement amount of$7,750,000.(~I.w)

24 Settlement Payments means the $2,500 Uber has agreed to pay Plaintiff Steven Price

25 in exchange for a general release ofclaims, and the $17,500 Uber has agreed to pay

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Hani Aly in exchange for a general release of claims. The Settlement Payments will

not be deducted from the Settlement Sum and will be paid separately by Uber to Price

and Aly.(TI.x)

• The Net Settlement Amount($4,650,000) means the Settlement Sum less:

• Up to $2,325,OGO(30%)for fees and costs to Plaintiffs' counsel (IIII.C.a.1);

• Up to $775,000 for claims administration (111I.C.a.2).

• Ofthe Net Settlement Amount $775,000 will be allocated to Labor Code §558

penalties, 100% of which will be distfibuted to PAGA Settlement Group Members as

Section 558 Penalties. Of the remaining $3,875,000,75% will go to the LWDA

($2,906,250)and the other 25% will go to the PAGA Settlement Group Members

($968,750).' (T1II.C.a.3)

• The amount paid to each PAGA Settlement Group Member will be determined by

first dividing the Net Settlement Amount2 by the total number of Active Weeks for

all PAGA Settlement Group Members during the relevant period (July 8, 2013 —

January 29,2017)to arrive at the "Active Week Amount" and then multiplying each

Settlement Group Member's total number of Active Weeks by the Active Week

Amount.(TIII.C.a.3)

• Driver Penalty Payments will be reported on IRS Form 1099. PAGA Settlement

Group Members will be responsible for paying all applicable state, local and federal

income taxes on all amounts received pursuant to this settlement and shall not seek

any indemnification from the Released Parties.(~IILC.e)

$775,000 Section 558 penalties plus $968,750 PAGA penalties equals $1,743,750.

Counsel confirmed at oral argument that this is meant to refer to the $1,743,750 amount rather

than the $4,650,000 Net Settlement Amount.

5
Upon entry ofthe Final Order, Plaintiff, Aly, all PAGA Settlement Group Members,

and the State of California shall be deemed to have fully, finally, and forever waived,

released, relinquished, and discharged each and all ofthe Released Parties from any

and all PAGA Claims as defined herein that arose or may be alleged to have arisen at

any time from July 8,2013 up to and including January 29, 2017. Specifically, in

exchange for the payments described above, Plaintiff and Aly, on behalf of

themselves, the State of California, and the PAGA Settlement Group Members, will

release Defendants from liability for any and all claims for civil penalties related to

alleged driver misclassification that might be brought under the PAGA based on

alleged violations of Labor Code §§ 226,226.3, 226.7. 226.8, 351, 353, 354,432.5,

450, 510, 512,551,552,558(not for wage claims), It 74, 1174.5, 1182.12, 1194,

1197, 1197.1, 1198, 1199, 2753, 2802, as well as under Wage Order No.9 only. The

release of penalties under section 558 ofthe Labor Code does not affect the

underlying wage claims. To the extent an alleged PAGA violation arises directly

from the operative facts pled in the Complaint and implicates the same primary rights

and defenses being settled here, those claims are settled and released to the fullest

extent permitted under applicable law. Nothing in the foregoing is meant to release

the PAGA claims pursuant to Labor Code sections 245-249 asserted in Tabola v.

Uber Technologies, Inc., et al., San Francisco Superior Court Case No. CGC-16-

550992.(IV.C)

o PAGA Claims means,"claims for PAGA penalties that:(1)arose or may

be alleged to have arisen at any time from July 8, 2013 up to and

including January 29,2017,and are (2)are (sic) based on or arise from

alleged violations ofthe following Labor Code provisions: 226,226.3,

226.7, 226.8, 351,353, 354,432.5, 450,510, 512, 551, 552,558 (not for

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I wage claims), 1]74, 1174.5, 1182.12, 1194, 1197t 1197.1, 1198, 1199,

2 2802, and 2753; claims under Business and Professions Code section

3 violations, and the California Code of Regulations and/or Industrial

4 Welfare Commission Wage Orders, including but not limited to Wage

5 Order 9-2001."(TI.r)

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C.The Nature of a PAGA Claim
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Briefly, and as set forth in more detail in the Court's September 14, 2017 Order, the
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PAGA was enacted to aid public agencies, which lack adequate funding, in enforcement of
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California's labor laws. While the full parameters of PAGA actions are not settled, it is clear
10
that private persons suing under the PAGA do so as a proxy ofthe state.(Arias v. Superior Court
II
(2009)46 Cal. 4" 969, 986.) Aggrieved employees suing under the PAGA are authorized to
12
recover certain civil penalties. Ofthe civil penalties recovered 75% goes to the LWDA,leaving
13
the remaining 25% for the "aggrieved employees." Labor Code § 2699 (a). Additionally,
14
because an aggrieved employee is acting on behalf of the state, the state is bound by any
15 1h
judgment entered in a PAGA action.(Arias,46 Cal.4 969 at 986.) However,the State and
16
other aggrieved employees authorized by the LWDA are also free to bring PAGA actions for
~ 17
alleged on-going violations for time periods outside the settlement period, as counsel
is
acknowledged at hearing. As to at least the LWDA,this includes claims for injunctive relief
19
D. The Legal Standard
20
Labor Code §2699(l)(2)requires courts to "review and approve any settlement of any
21
civil action filed pursuant to this part." No published case has determined the standards the
22
Court should employ in evaluating a PAGA settlement. The California Supreme Court explains
23
that a PAGA claim is a form of a qui tam action. Iskanian v. CLS Transportation Los Angeles
24 1h
LLC(2014)59 Cal.4 348,382. As such, this Court looks to qui tam standards in evaluating
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this settlement, i.e. whether the settlement is "fair, adequate, and reasonable" in the
circumstances. Cf Cal. Govt. Code § 12652(In a qui tam action a state or political subdivision
may settle the action with the defendant notwithstanding the objections ofthe qui tam plaintiff if

the court determines, after a hearing providing the qui tam plaintiff an opportunity to present

evidence, that the proposed settlement is fair, adequate, and reasonable under all ofthe

circumstances.) While PAGA actions are distinct from class actions,the class action standard

(fair, reasonable, and adequate settlement) is adopted here for these reasons.'

E. Application of the Standard

Based upon evidence presented in connection with the prior settlement agreement, the

following are the range of possible outcomes if Plaintiffs prevail at trial:

0 Only Active Drivers, no stacking, no subsequent penalties: $ 51,729,600

• Both Active and Applicants, no stacking, subsequent penalties: $ 2,024,928,400

• Only Active Drives, stacking but no subsequent penalties allowed: $ 3,103,776,000

0 Only Active Drivers, stacking, subsequent penalties allowed: $121,495,704,000

It is not suggested that further fact discovery is needed to understand the claims herein.

According to Plaintiffs' counsel the most likely outcome would be that the PAGA recovery in

this case is between $52 million and $1 billion if plaintiffs prevail in this action.(Declaration of

Christopher J. MorosoffISO prior PAGA settlement,19.)The proposed $7,750,000 settlement

represents approximately 15% of the low value estimate($52 million) and .77% ofthe highest

value ($1 billion).

As the Court previously noted, this case is unusual in that the outcome as to liability

uncertain, as is the range of possible relief. Further, it could be many years before the legal issue

are settled. The objection and reply arguments reinforce the unsettled nature ofthe claims being

resolved. The range of value ofthe claims could be zero, as in some ofthe arbitration awards, or

8
it could be $121 billion if Plaintiffs were completely successful at trial, the maximum penalties

were assessed, and either no appeal is taken or the judgment is affirmed on appeal.

The $7.75 million PAGA settlement is fair,just and reasonable in all the circumstances,

including that adequate discovery has been done; even if plaintiffs prevail, trial courts have

discretion to award less than the maximum penalties to avoid unjust, arbitrary, oppressive or

confiscatory awards; the unsettled nature ofthe legal question (whether drivers are employees)

and the likelihood ofappeal if plaintiffs' prevail; the experience of counsel; the fact that the

settlement does not preclude PAGA claims for time periods after January 29,2017, allowing the

question of employee status to be further litigated; and the fact that the real party in interest

(LWDA)did not express any objection to the settlement.(i~f Kullar v. Fool Locker Relail, Inc.

(2008) 168 Cal.AppAth 116.)

In this regard, the Court acknowledges that in its experience LWDA has not traditionally

"weighed in" on PAGA settlements. While it can be argued that this is because it does not have

the resources to do so(the very reason for the PAGA statute), it is statutorily required that notice

ofany proposed settlement be given to the LWDA (Labor Code §2699(l)(2)), thus suggesting

that it may object if it finds a settlement deficient. Further, at the Court's invitation LWDA

filed an amicus brief earlier in this case. Thus, at least for purposes of this motion, it is

significant that LWDA has not commented on this particular settlement and also elected to take

no position on the ultimate propriety ofthe earlier proposed settlement.

In approving the settlement, the Court considered the objection filed on behalf of the

class in O'Connor, which essentially challenges the amount ofthe settlement and charges that

the settlement is collusive, the product of a reverse auction, and constitutes inappropriate forum

shopping.

No evidence is tendered that supports the charge that a reverse auction was conducted.

The settlement was negotiated by an experienced retired judicial 'officer. There is no evidence

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that defendants' counsel "shopped" the settlement among lawyers representing others who had

been permitted by LWDA to bring claims on its behalf or dealt with the weakest only, which are

the hallmarks ofa "reverse auction."

The Court is likewise not persuaded that the settlement is the product ofinappropriate

forum shopping. A proposed settlement in O'Connor (tendered by the same counsel who is now

objecting to the amount of the settlement herein) included a proposal that the parties' amend the

complaint to include a PAGA claim and settle the PAGA claim for $1,000,000. This was

rejected by the District Court. Apparently, counsel in O'Connor then suggested that the PAGA

claim could be settled for $11 million if she waived a portion of her fee, The District Court

indicated, in dicta, that a PAGA settlement of $11 miIlion would amount to 1.1% of the

potential verdict value and"would take away funds that otherwise would have gone to drivers,

putting the burden of supporting the public interest on the employee rather than the employer."

(Spurchise Declaration filed February 1, 2017 113 and Exhibit 10 thereto: Order Denying

Plaintiffs' Motion for Preliminary Approval, page 33, FN 21.).

A decision thereafter to negotiate settlement ofthe claims in a case in which the claims

were actually pled (and have been pled since 2014)cannot be considered inappropriate forum

shopping. This is particularly true because the District Court has made clear that it intends to

defer to this Court with respect to settlement ofthe PAGA claims in this action.

Further, the O'Connor class' argument that the Court should decline to approve the

settlement because the California Supreme Court has requested briefing and set oral argument

concerning the criteria for determining independent contractor status in an unrelated action

(Dynamex Operations West, Inc. v. Superior Court, Case No. S222731) is an insufficient reason

for denying approval of this settlement. The Court must assess this case under the current law.

The Court has also considered the objections ofcounsel in the ded Rio matter to the effect

that the settlement is inadequate in amount; does not consider additional exposure for liability;

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 and seeks "expedited" relief The arguments regarding the amount of the settlement are rejected,

for the reasons set forth above. The balance ofthe arguments are factually inaccurate. The

liability period under the settlement ends at January 29, 2017,as counsel acknowledged at oral

argument. Further, the settlement is being considered after a regularly noticed motion. Nothing

was "expedited."

F. Request for Dismissal

The Declaration of Douglas Caiafa sufficiently supports the Request for Dismissal. Cal.

Rules of Court, Rule 3.770. The Court is satisfied that dismissal ofthe class claims will not

prejudice absent class members as other actions assert the same claims. Further, given that Price

and Aly are signing general releases and given the amounts in controversy respecting their

individual claims, the separate payments to them do not suggest collusion and are not in the

nature of incentive payments.

G. Request for Attorneys' Fees

Attorneys Morosoff and Caiafa request an award offees and costs in an amount up to

30% of the $7.75 million PAGA settlement, or $2,325,000. Fee awards based on a percentage

ofthe settlement are permitted in the class action arena and arguably in the PAGA arena as well.

A fee of one third of the total settlement is within the range of what may be considered average,

at least in a class action.(In re ConTumer Privacy Cases(2009) 175 Cal.AppAth 545,558,

FN 13:"Empirical studies show that, regardless whether the percentage method or the lodestar

method is used, fee awards in class actions average around one-third of the recovery.")

A lodestar crosscheck confirms the reasonableness of the fee request here. Attorney

Morosoff has filed three declarations in support ofthe fee award, two in connection with the

prior proposed settlement and one in connection with the amended settlement. Morosoffattaches

copies of his prior declarations to his current declaration. The total time spent on this litigation

i71, II

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(PAGA claim only) as evidenced in these three declarations is 1,580 hours. At his hourly rate of

$650 this is a lodestar of$1,028,300. Attorney Caiafa's hours. are likewise calculated by way of

three declarations; they total 1,505 hours. At Caiafa's $750 hourly rate, his lodestar is

$1,131,760. The combined lodestar amount is $2,160,060. No objection to the amount of the

fees was tendered by LWDA or the objectors. The Court finds that the fee request is reasonable

and awards the combined $2,325,000 fee and cost request.

111. CONCLUSION AND ORDER

1. The settlement set forth as Exhibit A to the Joint Motion filed December 21, 2017 is

approved as fairJust and reasonable.

2. The request to amend the Complaint is granted.

3. Counsel are to provide a proposed form of Judgment and Orders of Dismissal on or

before February 1, 2018.

4. A status conference in the remaining related cases will be heard on March 22,2018 at

1:45 p.m.

Counsel for Uber shall give notice.

I
Dated:
MAREN E. NELSON

Judge ofthe Superior Court

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 1 Documents Considered:

3 Lodged Jointly by both parties November 21,2017

4 Stipulation and Order for Filing First Amended Complaint

5 Joint Stipulation for Approval ofPAGA Settlement

7 Filed by Plaintiff November 21,2017

8 Declaration of Douglas Caiafa in Support ofStipulation for Filing First Amended Complaint

9 Declaration of Douglas Caiafa in Support of Joint Stipulation for Approval ofPAGA Settlement

10 and Attorneys' Fees and Costs(and attached exhibits, consisting of copies of documents filed in

11 connection with hearings for approval of the prior settlement)

12 -Supplemental Declaration of Steven Price in Support of Request for Approval ofPAGA

13 Settlement

14 -Supplemental Declaration of Hani Aly in Support of Request for Approval ofPAGA

15 Settlement

16 -Further Supplemental Declaration of Steven Price in Support of Request for Approval of

17 PAGA Settlement

18 -Further Supplemental Declaration of Hani Aly in Support of Request for Approval of

19 PAGA Settlement

20 -Declaration of Douglas Caiafa in Support of Plaintiffs' Request for Approval of

21 Attorneys' Fees and Costs re Joint Request for Approval ofPAGA Settlement

22 -Supplemental Declaration of Douglas Caiafa in Support of Joint Request for Approval o'

23 PAGA Settlement and Attorneys' Fees and Costs

24 -Declaration of Christophe J. Morosoff in Support of Joint Request for Approval of

.25 PAGA Settlement, Request to Dismiss Entire Action, and Plaintiffs' Request for

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Approval of Attorneys' Fees and Costs re Joint Stipulation for Approval ofPAGA

Settlement

-Supplemental Declaration of Christophe J. Morosoff in Support of Joint Request for

Approval ofPAGA Settlement, Request to Dismiss Entire Action, and Plaintiffs' Request

for Approval of Attorneys' Fees and Costs re Joint Request for Approval ofPAGA

Settlement

Declaration of Christopher J. Morosoff in Support of Joint Stipulation for Approval ofPAGA

Settlement

Plaintiffs' Request to Dismiss Entire Action Including Individual and Putative Class Claims

Filed Jointly by both parties December 21,2017

Notice of Joint Motion and Motion for Joint Approval ofPAGA Settlement

Memorandum of Points and Authorities in Support of Joint Motion for Approval ofPAGA

Settlement

Filed by Defendant December 21,2017

Declaration of Rachel Lavi in Support of Joint Motion for Approval ofPAGA Settlement

Filed by Plaintiff December 21,2017

Declaration of Douglas Caiafa in Support of Joint Motion for Approval ofPAGA Settlement and

Attorneys' Fees and Costs(and attached exhibits, copies of previously filed documents)

Declaration of Christophe J. Morosoff in Support of Joint Stipulation for Approval ofPAGA

Settlement(and attached exhibits, copies of previously filed documents)

Plaintiffs' Request to Dismiss Entire Action Including Individual and Putative Class Claims

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Filed by Defendant December 22,2017

Supplemental Declaration of Rachel Lavi in Support of Joint Motion for Approval of PAGA

Settlement(re: submission ofthe amended settlement agreement, motion, and proposed order to

the LWDA,and attached exhibit showing successful submission)

Filed by O'Connor Class January 5,2018

Certified O'Connor Class' Renewed Objection

Filed by Plaintiff January 10,2018

Plaintiff Steven Price's Reply in Support of Joint Motion for Approval ofPAGA Settlement

Filed by Defendant January 10,2018

Defendants Uber Technologies, Inc. and Raiser-Ca, LLC's Reply to 0'Connor Class' Renewed

Objection to Settlement

Declaration of Rachel Lavi in Support of Defendants' Reply to O'Connor Class' Renewed

Objection to Settlement

Filed by Del Rio Class January 12,2018

Objection to Stipulation for Approval ofPAGA Settlement

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