united states district court southern district of … · macias v. water & power community...

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO 1:19-CV-23028-DPG

AMANDA DEFRANKS and KATHERINE FOWLER, individually and on behalf of all others similarly situated, Plaintiffs, v. NASTYGAL.COM USA INC, Defendant, _____________________/

CLASS ACTION JURY TRIAL DEMANDED

DECLARATION IN SUPPORT OF UNOPPOSED MOTION FOR PRELIMINARY APPROVAL OF CLASS SETTLEMENT AND

CERTIFICATION OF SETTLEMENT CLASS Scott A. Edelsberg declares as follows:

1. I am one of the attorneys requesting to be designated as Class Counsel for Plaintiffs

under the Settlement Agreement and Release (“Settlement” or “Agreement”) entered into with

Defendant.1 I submit this declaration in support of Plaintiffs’ and Class Counsel’s Unopposed

Motion for Preliminary Approval of Class Settlement and Certification of Settlement Class. Except

as otherwise noted, I have personal knowledge of the facts set forth in this declaration, and could

testify competently to them if called upon to do so.

2. In my professional opinion, the Parties’ proposed Settlement is exceedingly fair,

and well within the range of preliminary approval for several reasons.

1 All capitalized defined terms used herein have the same meanings ascribed in the Agreement.

Case 1:19-cv-23028-DPG Document 35-2 Entered on FLSD Docket 05/05/2020 of 15

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3. The Settlement was not conditioned on any amount of attorneys’ fees for Class

Counsel or Service Awards for Plaintiffs, which speaks to the fundamental fairness of the process.

4. The Claims Process here is straightforward, easy to understand for Settlement Class

members, and designed so that they can easily claim to their portion of the Settlement Fund.

5. A preliminary review of the factors related to the fairness, adequacy and

reasonableness of the Settlement demonstrates that it fits well within the range of reasonableness,

such that Preliminary Approval is appropriate.

6. Plaintiffs and their counsel believe that the claims asserted are meritorious and that

Plaintiffs would prevail if this matter proceeded to trial. Defendant argues that Plaintiffs’ claims

are unfounded, denies any liability, and has shown a willingness to litigate vigorously.

7. The Parties concluded that the benefits of the Settlement outweigh the risks and

uncertainties attendant to continued litigation that include, but are not limited to, the risks, time

and expenses associated with completing trial and any appellate review.

8. The Settlement here is the result of extensive, arm’s-length negotiations between

experienced attorneys who are familiar with class action litigation and with the legal and factual

issues of this Action.

9. Plaintiff’s counsel are particularly experienced in the litigation, certification, trial,

and settlement of nationwide class action cases. See Firm Resumes attached as composite Exhibit

1.

10. Plaintiffs’ counsel zealously represented their client throughout the litigation, and

throughout the discovery process, which included review of numerous pages of documents and

electronic data.

11. Plaintiffs’ counsel conducted a thorough analysis of Plaintiffs’ claims and engaged

in extensive formal discovery with Defendant.


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12. Plaintiffs’ counsel are confident in the strength of Plaintiffs’ case, but are also

pragmatic in their awareness of the various defenses available to Defendant, and the risks inherent

in trial and post-judgment appeal.

13. Plaintiffs’ counsel appropriately determined that the Settlement outweighs the risks

of continued litigation.

14. There should be no doubt that this Settlement is a fair and reasonable recovery for

the in light of Defendant’s defenses, the uncertainty of class certification, and the challenging and

unpredictable path of litigation Plaintiff and all Settlement Class members would face absent a

settlement.

15. I strongly believe the Settlement is the best vehicle for Settlement Class Members

to receive the relief to which they are entitled in a prompt and efficient manner.

16. Plaintiffs’ counsel were extremely well-positioned to confidently evaluate the

strengths and weaknesses of Plaintiffs’ claims and prospects for success at trial and on appeal.

* * *

I declare under penalty of perjury of the laws of Florida and the United States that the

foregoing is true and correct, and that this declaration was executed in Aventura, Florida, on May

5, 2020.

/s/ Scott A. Edelsberg Scott A. Edelsberg


EXHIBIT 1


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ABBAS KAZEROUNIAN Kazerouni Law Group, APC

EDUCATION: California Western School of Law, San Diego, California J.D., 2006 University of Plymouth, United Kingdom B.A., Bachelor of Arts - 2000 The London Academy of Performing Arts - 2001 PROFILE: Mr. Kazerounian is one of the founding partners of Kazerouni Law Group, APC

(KLG), which was established in 2007. KLG is a consumer rights and personal injury firm with offices in Arizona, California, Nevada, Texas and Utah. Mr. Kazerounian is a member of several consumer rights organizations and currently serves on the executive committee as diversity chair at Consumer Attorneys of California. He is also an adjunct professor at California Western School of Law.

BAR ADMISSIONS: State: California, Colorado, District of Columbia, Illinois, New York, Texas,

Michigan, Washington

Federal: Southern District of California, Central District of California, Eastern District of California, Northern District of California, District of Colorado, Northern District of Illinois, Eastern District of Washington, Western District of Washington, Northern District of Texas, Eastern District of Texas, Ninth Circuit Court of Appeals, Eighth Circuit Court of Appeals, U.S. Supreme Court

EXPERIENCE: Mr. Kazerounian has 13 years’ experience in representing plaintiffs in consumer

litigation, having litigated over 4,000 individual consumer rights cases. A respected consumer rights class action attorney. Some of his more notable cases in the consumer and privacy class action space include: Ahmed et al. v. HSBC Bank USA, et al., 5:15-cv-02057-FMO-SP (C.D. Cal. Dec. 30, 2019) (Class counsel in finally approving TCPA class action settlement of $2,400,000); Smith v. One Nev. Credit Union, 2:16-cv-02156-GMN-NJK, 2019 U.S. Dist. LEXIS 54963 (D. Nev.) (finally approved Fair Credit Reporting Act class action settlement for $600,000 on March 29, 2019); Swigart v. Parcel Pending, Inc., 3:18-cv-02238-BEN-WVG (S.D. Cal.) (granting final approval to surreptitious call recording class action settlement); Holt et al. v. Foostate, Inc., 1:17-cv-00637-LM (D. NH) (Class counsel in finally approved false advertising action, with a common fund $2,100,000, on Jan. 16, 2020); McCurley et al. v. Royal Seas Cruises, Inc., 17-cv-00986-BAS-AGS (S.D. Cal.) (certified class achieved by motion in TCPA class action on behalf of over 2 million class members, on July 31, 2018); Barrow v. JPMorgan Chase Bank, N.A., 1:16-cv-03577-AT (N.D. Ga.) (Class counsel in TCPA class action settlement with $2,250,000 common fund, finally approved on November 6, 2018); Giffin v. Universal Protein Supplements Corporation d/b/a/ Universal Nutrition et al., No. BC613414 (Sup. Ct. Los Angeles) (finally approved class action settlement in 2018 alleging violation of California Made in USA law); Medeiros v. HSBC Card Services, Inc. et al., 2017 U.S. LEXIS 178484 (C.D. Cal. Oct. 23, 2017) (finally approved surreptitious call recording class settlement for $13,000,000); Hooker v. Sirius XM Radio Inc., 4:13-cv-00003-AWA-LRL (E.D. Va., December 22, 2016)


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(co-lead counsel in finally approved TCPA class action settlement with fund of $35,000,000); Gehrich v. Chase Bank, N.A., 12-cv-5510 (N.D. Cal.) (co-lead counsel in finally approved TCPA class action settlement for $34,000,000); Newman v. AmeriCredit Financial Services, 11-cv-03041-DMS-BLM (S.D. Cal.) (Co-lead counsel in finally approved TCPA settlement for over $6,500,000 on March 28, 2016); Chen v. Allstate Ins. Co., 819 F.3d 1136 (9th Cir. 2016) (order affirming decision finding unaccepted offer of judgment under Fed. R. Civ. P. 68 did not moot the plaintiff’s individual claims); Macias v. Water & Power Community Credit Union, BC515936 (Sup. Ct. Los Angeles) (final approval in Rosenthal Fair Debt Collection Practices Act class settlement in 2016); Mount v. Wells Fargo Bank, N.A., BC395959 (Sup. Ct. Los Angeles) (final approval of surreptitious call recording class action for $5,600,000); Oxina v. Lands’ End, Inc., 3:14-cv-02577-MMA-NLS (S.D. Cal. 2016) (finally approved settlement under California Made in the USA statute); LaPuebla v. BirchBox, Inc., 3:15-cv-00498-BEN-BGS (S.D. Cal. 2016) (finally approved settlement in auto-renewal violation action); Mills v. HSBC Bank Nevada, N.A., Case No. 12-CV-04010-SI (N.D. Cal.) (finally approved TCPA class action settlement for $39,975,000); Hoffman v. Bank of America Corporation, 12-CV-00539-JAH-DHB (S.D. Cal.) (co-lead counsel in California class action settlement under Penal Code 632, et seq., with a common fund of $2,600,000, finally approved on November 6, 2014); In Re: Portfolio Recovery Associates, LLC Telephone Consumer Protection Act Litigation, 11-md-02295-JAH (BGS) (Counsel for a plaintiff in the lead action, prior to the action being recategorized through the multi-district litigation process); In Re: Midland Credit Management, Inc., Telephone Consumer Protection Act Litigation, 11-md-2286-MMA (MDD) (S.D. Cal.) (Counsel for a plaintiff in the lead action, prior to the action being recategorized through the multi-district litigation process; finally approved for $18,000,000); Malta, et al. v. Wells Fargo Home Mortgage, et al., 10-CV-1290-IEG (BLM) (Served as co-lead counsel for a settlement class of borrowers in connection with residential or automotive loans and violations of the TCPA; common settlement of $17,100,000, final approval granted in 2013).

Prior experience in data breach litigation in McAfee et al. v. Treasure Island, LLC, No. A-18-772302-C, 2019 Nev. Dist. LEXIS 421 (D. Nev.) (final class action settlement approval granted on May 23, 2019); Santana et al., v. Rady Children’s Hospital - San Diego, No. 37-2014-00022411-CU-MT-CTL (granting final class action settlement approval on February 8, 2019); Barajas v. First American Financial Corporation et al., 8:19-cv-01078-DSF-E (C.D. Cal.). Appointed co-Lead Counsel in a federal securities class action in Jiao et al. v. Merrill Lynch Pierce Fenner & Smith, Inc. et al., No. 3:17-cv-00409-L-MDD (S.D. Cal.). Presented oral argument before the Ninth Circuit Court of Appeals in Marks v. Crunch San Diego, LLC, No. 14-56834 (December 6, 2016), with a unanimous published decision in favor of client, Marks v. Crunch San Diego, LLC, No. 14-56834, 2018 U.S. App. LEXIS 26883 (9th Cir. Sept. 20, 2018); Knutson v. Sirius


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XM Radio, Inc., No. 12-56120 (February 7, 2014); and twice in Afewerki v. Anaya Law Group, Nos. 15-55100 (April 7, 2017) and 56510 (May 15, 2019). Prior experience in products liability litigation, obtaining a $2,500,000 settlement in 2008 in Mei Lu Hwei, et al. v. American Honda Motor Co., Inc., et al., BC401211 (Sup. Ct. Los Angeles).

HONORS & AWARDS: Wiley W. Manuel Award by State Bar of California for Pro Bono Work, 2017;

Voted Rising Star in Super Lawyers Magazine, 2013-2015; Voted a Super lawyer in Super Lawyer Magazine 2016-2019; Voted Rising Star by San Diego Transcript in 2012; Nominated to Top 40 under 40 by The National Trial Lawyers 2018-2019.

PUBLICATIONS: Articles: Collateral Damage, Beyond the personal injury: When Creditors and

collection agencies stalk your client, Plaintiff magazine, 2017; Finding A Balance, Nutrition Business Journal, Special Edition, 2016; FDCPA: The Forgotten Statute, Daily Journal, 2016; Principles of Litigating Consumer Class Actions, The Advocate, February 2015

Books: Boy with Two Lives, 2015; On Two Feet and Wings, 2013

SPEAKING ENGAGEMENTS: Presented at the following events on legal topics: Webinar on “Data Breach

Basics,” Consumer Attorneys of California, April 2020; speaker at San Diego Law School Action Forum 2020, “Consumer Class Actions,” March 2020; Webinar on “Recent Developments in Internet and Privacy Law Affecting California Consumer Financial Service Providers,” California Lawyers Association, March 2020; Fundamentals of the FDCPA, National Consumer Law Center 2019 Las Vegas Conference; “The interplay between Personal Injury and Class Actions,” Consumer Attorneys of California, Sonoma Seminar 2019; Mass Torts Made Perfect on Modern Trends in the TCPA, April 2019; Consumer Financial Services Committee meeting entitled, TCPA Litigation: Where Is It Heading Now?, Jamuary 11, 2019; panelist at a webinar, TCPA Takes A New Turn With the 9th Circuit’s Ruling in Marks v. Crunch San Diego, LLC, hosted by the Consumer Financial Services Committee of the American Bar Association, October 10, 2018; National webinar sponsored by Ballard Spahr LLP, entitled, From Both Sides: Plaintiff and Defense Perspectives on the TCPA, August 2018; Inland Empire CAOC Convention on “Class Action Hot Topics,” May 2018; National Webinar by the ABA Consumer Financial Services Committee on TCPA Update – “The D.C. Circuit’s TCPA Decision on the FCC Ruling, March 22, 2018; moderated the Judges Panel on Class Action Trends and Federal Litigation Trends at the NCLC Conference, March 2016; lectured on the TCPA before the ABA Business Law Section, Consumer Financial Services Committee in January 2016 at an event in Utah entitled, “Impact of the FCC’s 2015 Rulings on TCPA Litigation”; lectured in Class Action Trends at the CAOC 2015 Conference in San Francisco, California; panelist in a webinar, ABA Telephonic Brown Bag re: TCPA, August 25, 2015; ABA TCPA National


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Webinar (Consumer Protection, Privacy & Information Security, Private Advertising Litigation, and Media & Technology Committees), September 2013. Speaker at various law schools, including Whittier Law School, Chapman Law School, University of California, Irvine, and California Western School of Law. Often called upon to appear on radio and television shows to offer legal analysis, including on Dr. Drew Midday Live and Fox 5.


Gattinella v. Michael Kors

Wildstein v. Seventh Generation, Inc.,

Gottlieb v. CITGO Petroleum Corporation

Seth F. Masson v. Tallahasse Dodge Jeep Chrysler, LLC

Jeanne and Nicolas Stathakos v. Columbia Sportswear Company

Jessica Dipuglia v. US Coachways, Inc.,

Zoey Bloom v. Jenny Craig Inc.


Shamis & Gentile, P.A. | 1

Our Firm Shamis & Gentile, P.A. has and continues to provide outstanding legal services in the Florida, New York and Texas communities. Shamis & Gentile, P.A. distinguishes itself because of our experience and legal resources to handle virtually any case involving class action, personal injury, personal injury protection, and contract disputes. Specifically, as it relates to class actions, Shamis & Gentile, P.A. has filed and litigated hundreds of TCPA, FACTA, FCRA, Banking, and insurance breach of contract lawsuits. At Shamis & Gentile, P.A. our seasoned attorneys are some of the most innovative and progressive attorneys in the profession. Often, Shamis & Gentile, P.A. is called upon to litigate and settle cases that other law firms may not be able to handle on their own.

Shamis & Gentile, P.A is committed to practicing law with the highest level of integrity in an ethical and professional manner. We are a diverse firm with lawyers and staff from all walks of life. Our lawyers and other employees are hired and promoted based on the quality of their work and their ability to treat others with respect and dignity.

Who We Are Andrew Shamis is the managing partner at Shamis & Gentile P.A. Mr. Shamis has extensive experience in civil ligation (county, circuit and federal) where he has gained a reputation as an aggressive attorney who advocates for his clients in the strongest way possible. Mr. Shamis has successfully litigated cases (including positive trial verdicts) throughout the United States. Mr. Shamis has been personally responsible for recovering tens of millions of dollars owed to his clients over the course of his legal career. Mr. Shamis is admitted to practice law in both the state of Florida and New York, as well as the U.S. District courts for the Southern, Middle, and Northern Districts of Florida, Northern District of Illinois, Eastern District of Michigan, Northern District of Ohio, Western District of Wisconsin, and Western District of Oklahoma. Mr. Shamis specializes in Class Action Litigation (TCPA, FACTA, FCRA, Banking, and insurance breach of contract), Personal Injury, Personal Injury Protection, Wrongful Death, as well as General Civil Litigation.

Angelica Gentile is a named partner at Shamis & Gentile, P.A. Ms. Gentile heads the catastrophic injury and personal injury protection departments of Shamis & Gentile, P.A. Ms. Gentile is a consistent favorite among clients as her ability to successfully protect their interests and advocate on their behalf through successful litigation (which has resulted in the recovery of


millions of dollars owed) throughout the state of Florida. Ms. Gentile is admitted to practice law in Florida and Texas, the U.S. District Courts for the Southern and Middle Districts of Florida, and U.S. District Courts for the Northern, Western, Eastern, and Southern Districts of Texas.

Ms. Gentile specializes in Personal Injury, Personal Injury Protection, Class Action Litigation (TCPA, FACTA, and insurance breach of contract), Wrongful Death, Wrongful Termination, as well as General Civil Litigation.

Our staff sets the standard on being innovative and technologically savvy. This innovation and use of fully customized cutting-edge case management software allows us to create an unparalleled level of customer service and attention to detail with our clients, which has led to an exceptional growth rate rarely seen in law firms. Shamis & Gentile, P.A. has the resources, infrastructure and staff to successfully represent large putative classes. The attorneys and staff are not simply litigators, but directors of creating successful results with the ultimate level of satisfaction by the clients. Class Actions Shamis & Gentile has initiated and served as both lead counsel and co-lead counsel in hundreds of class actions, many of which have generated internet articles. Currently, the firm serves as lead counsel of co-counsel on over 100 class action lawsuits. The lawsuits range from all Districts of Florida to the Central District of California. Shamis & Gentile, P.A. has also successfully settled many Class Action cases prior to verdict. Prominent Class Action Settlements

Over the years, Shamis & Gentile attorneys have obtained outstanding results in some of the most well-known cases.

• Bloom v. Jenny Craig, Inc., No. 1:18-cv-21820-KMM, 2018 U.S. Dist. LEXIS 151686

(S.D. Fla. Sep. 6, 2018) ($3,000,000.00 Class Settlement)

• Papa v. Greico Ford Fort Lauderdale, LLC, No. 1:18-cv-21897 (S.D. Fla. 2018) ($4,800,000.00 Class Settlement)

• Poierier v. Cubamax Travel Inc., No. 1:18-cv-231240 (S.D. Fla. 2018) ($808,734.00 Class

Settlement)

• Marengo v. Miami Resch. Assocs., LLC, No. 1:17-cv-20459-KMW, 2018 U.S. Dist. LEXIS 122098 (S.D. Fla. July 20, 2018) ($1,236,300.00 Class Settlement)


• Whitworth v. HH Entm't, Inc., No. 9:17-cv-80487-KAM, 2018 U.S. Dist. LEXIS 112223 (S.D. Fla. July 6, 2018) ($750,000.00 Class Settlement)

• Dipuglia v. US Coachways, Inc., No. 17-23006-Civ, 2018 U.S. Dist. LEXIS 72551 (S.D.

Fla. Apr. 30, 2018) ($2,600,000.00 Class Settlement)

• Rattner v. Tribe App. Inc., No. 17-cv-21344, 2017 U.S. Dist. LEXIS 198517 (S.D. Fla. Nov. 30, 2017) ($200,000.00 Class Settlement)

• Gottlieb v. Citgo Corporation, No. 16-cv-81911 (S.D. Fla. 2016) ($8,300,000.00 Class

Settlement)

• Eisenband v. Schumacher Automotive, Inc., No. 18-cv-01061 (S.D. Fla 2018) ($5,000,000.00 Class Settlement)

• Wijesinha v. Susan B. Anthony List, Inc. No. 18-cv-22880 (S.D. Fla. 2018) ($1,017,430.00

Class Settlement)

• Albrecht v. Oasis Power, LLC, No. 1:18-cv-1061 (N.D. Ill. 2018) ($7,000,000.00 Class Settlement)

• Halperin v. YouFit Health Clubs, LLC, No. 18-CV-61722-WPD (S.D. Fla. 2018) ($1,418,635.00 Class Settlement)

• Prieto v. Crete Carrier Corporation, No. 19-CV-60903-BB (S.D. Fla. 2019) ($600,000.00 Class Settlement)

• Bellenger v. Accounts Receivable Management, Inc., No. 19-cv-60205-DIMITROULEAS (S.D. Fla. 2019) ($425,000.00 Class Settlement)

• Suarez v. MAPFRE Insurance Company of Florida, No. 19-02729-CA-01 (11th Judicial Circuit, Miami-Dade County) ($633,525.25 Class Settlement)

• Avila-Preciado v. Horace Mann Property and Casualty Insurance Company, No. 19-CA-004683 (20th Judicial Circuit, Lee County) ($150,000.00 Class Settlement)

• Mary Mclean v. Brett A. Osborn, D.O., PLLC, No. 18-cv-81222-DMM (S.D. Fla. 2018) ($800,000.00 Class Settlement)

• Picton v. Greenway Chrysler-Jeep-Dodge Inc. d/b/a Greenway Dodge Chrysler Jeep, No. 19-cv-00196-GAP-DCI (M.D. Fla. 2019) ($2,745,000.00 Class Settlement)


• Pena v. John C. Heath, Attorney at Law, PLLC, d/b/a Lexington Law Firm, No. 18-cv-24407-UU (S.D. Fla. 2018) ($11,450,863.00 Class Settlement)

Other Areas of Practice Shamis & Gentile, P.A. also litigates a variety of other types of litigation, including personal injury protection (of which they are considered the industry standard of excellence), personal injury, employment law, mass tort, breach of contract and health law. More About Shamis & Gentile, P.A. To learn more about our firm, please visit www.shamisgentile.com, or view links to our blogs at https://www.instagram.com/sfiattorneys/?hl=en.


http://www.shamisgentile.com/

https://www.instagram.com/sfiattorneys/?hl=en

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JASON IBEY Kazerouni Law Group, APC

EDUCATION: Whittier Law School, Costa Mesa, CA Juris Doctor – 2012 California State University, Fullerton B.A., Bachelor of Arts – 2009 PROFILE: Mr. Ibey recently became a partner at Kazerouni Law Group, APC (KLG). KLG is

a consumer rights and personal injury firm with offices in Arizona, California, Nevada, Texas and Utah. Mr. Ibey is a member of the Association of Consumer Advocates, and Consumer Attorneys of California.

BAR ADMISSIONS: State: California, Utah, Massachusetts

Federal: Southern District of California, Central District of California, Eastern District of California, Northern District of California, District of Utah, District of Massachusetts, Ninth Circuit Court of Appeals

EXPERIENCE: Mr. Ibey has 7+ years’ experience in representing plaintiffs in consumer litigation,

having litigated hundreds of consumer rights cases. Some of his more notable cases in the consumer and privacy class action space include: Holt et al. v. Foostate, Inc., 1:17-cv-00637-LM (D. NH) (Class counsel in finally approved false advertising action, with a common fund $2,100,000, on Jan. 16, 2020); Barrow v. JPMorgan Chase Bank, N.A., 1:16-cv-03577-AT (N.D. Ga.) (Class counsel in TCPA class action settlement with $2,250,000 common fund, finally approved on November 6, 2018); Ronquillo v. TransUnion Rental Screening Solutions, Inc. et al., 3:17-cv-00129-JM-BLM (S.D. Cal. May 9, 2020) (Class counsel in finally approved class settlement concerning claims under Cal. Pen. Code § 632.7, with a $425,000 common fund); Couser v. Dish One Satellite, LLC, 5:15-cv-02218-CBM-DTB (C.D. Cal. Nov. 21, 2017) (Class counsel in finally approved TCPA class settlement with a common fund of $935,000); Fox v. Spectrum Club of Santa Barbara, 16CV00050 (Sup. Ct. Santa Barbara) (Class counsel in finally approved TCPA class settlement on Mar. 24, 2017); Macias v. Water & Power Community Credit Union, BC515936 (Sup. Ct. Los Angeles) (counsel in finally approved class settlement in 2016 under the Rosenthal Fair Debt Collection Practices Act). Presented oral argument before the Ninth Circuit Court of Appeals in Self-Forbes v. Advanced Call Center Technologies, LLC, No. 17-15804 (oral argument held on August 16, 2018; obtained reversal of defendant’s motion for summary judgment); Carter v. Rent-A-Center, Inc., No. 16-15835 (oral argument held on October 20, 2017)

HONORS & AWARDS: Voted Rising Star in Super Lawyers Magazine, Consumer Law, 2018-2020 PUBLICATIONS: Articles: Pay your arbitration fees on time or lose the right to arbitration, Daily

Journal, October 2019; California’s Invasion of Privacy Act, Plaintiff magazine,


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May 2018; Think twice before filing that Article III challenge, Daily Journal, November 2016; Those annoying robo calls and the changing standard of prior express consent, Plaintiff magazine, March 2015.


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