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EXHIBIT 4 Case 2:09-cv-00852-LA Filed 06/09/15 Page 1 of 42 Document 688-4

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Page 1: EXHIBIT 4 - KCC Class Action

EXHIBIT 4

Case 2:09-cv-00852-LA Filed 06/09/15 Page 1 of 42 Document 688-4

Page 2: EXHIBIT 4 - KCC Class Action

107779

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

Fond Du Lac Bumper Exchange, Inc., and Roberts Wholesale Body Parts, Inc. on Behalf of Themselves and Others Similarly Situated, Plaintiffs, v. Jui Li Enterprise Company, Ltd., et al., Defendants.

Case No. 2:09-cv-00852-LA

DECLARATION OF JASON S. HARTLEY IN SUPPORT OF DIRECT PURCHASER

PLAINTIFFS’ MOTION FOR ATTORNEYS’ FEES AND REIMBURSEMENT OF EXPENSES FILED ON BEHALF OF STUEVE SIEGEL HANSON LLP

I, Jason S. Hartley, declare and state as follows:

1. I am a partner of the law firm of Stueve Siegel Hanson LLP. I submit this

declaration in support of Direct Purchaser Plaintiffs’ motion for an award of attorneys’ fees and

reimbursement of expenses in connection with the services rendered in this litigation. I make

this declaration based on my personal knowledge and if called as a witness, I could and would

competently testify to the matters stated herein.

2. My firm has served as counsel to the Direct Purchaser Class throughout the

course of this litigation. The background and experience of Stueve Siegel Hanson LLP and its

attorneys are summarized in the résumé attached hereto as Exhibit 1.

3. Stueve Siegel Hanson LLP has prosecuted this litigation solely on a contingent-

fee basis, and has been at risk that it would not receive any compensation for prosecuting claims

against the Defendants.

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4. During the course of this litigation, Stueve Siegel Hanson LLP has been involved

in the following activities on behalf of the Direct Purchaser Class at the request or under the

direction of Co-Lead Counsel:

Researched the law pertinent to the claims against Defendants and the potential

defenses thereto;

Researched the industry to determine propensity for anticompetitive conduct;

Prepared a detailed Second Amended complaint based on the extensive factual

and expert information Class Counsel collected;

Researched and drafted comprehensive briefs (and assembled supporting

materials) in opposition to Defendants’ motions to dismiss and for summary

judgment;

Prepared and served numerous discovery requests on Defendants;

Responded to numerous discovery requests propounded by Defendants including

responses to Defendants’ onerous contention interrogatories;

Briefed and argued multiple discovery disputes before this Court including

several sanction motions and at monthly status conferences;

Prepared and served subpoenas for the production of documents on third parties;

Engaged in the protracted negotiation of discovery issues with Defendants

including the negotiation of an ESI protocol, a Protective Order, document

custodians, keywords, and a search methodology;

Briefed and argued eight motions to compel against Defendants upon which

Plaintiffs prevailed in part or in total;

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Reviewed and analyzed hundreds of thousands of documents totaling millions of

pages of documents produced by Defendants and third parties in this litigation

including Chinese-language business records;

Prepared for and conducted numerous depositions including the interpreted

depositions of Defendants’ executives and employees in Taiwan;

Retained and consulted the preeminent antitrust economist, Dr. Russell Lamb, to

examine the economics of the aftermarket sheet metal industry, to analyze

Defendants’ transactional data, and prepare for class certification;

Conducted discovery regarding issues related to the Defendants’ transactional

data, including attorney proffers which were verified by Defendants as

interrogatory responses;

Managed an extensive document review including the training and oversight of

numerous document review attorneys, including Chinese-fluent bilingual

attorneys;

Conducted arm’s-length settlement negotiations with the Tong Yang Defendants

and Gordon Defendant over the course of months with the assistance of a

mediator;

Prepared and negotiated the Settlement Agreements;

Prepared the motions and briefs in support of Preliminary Approval of the Tong

Yang and Gordon Settlements;

Coordinated issuance of Notice and various settlement administration-related

matters with the Claims Administrator and with the escrow agent that is presently

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holding the Settlement Fund assets in an interest-bearing account for the benefit

of the Class; and

Communicated with the Class Representatives with updates on litigation status

throughout the course of the litigation.

5. Attached hereto as Exhibit 2 is a summary of my firm’s total hours and lodestar,

computed at historical rates, from case inception through April 30, 2015. Excluded from this

summary is time expended in preparing this fee and expense declaration. Exhibit 2 provides the

names of the attorneys and professional support staff who worked on this case, bar admission

year for each attorney, and each timekeeper’s respective hours and lodestar at historical rates.

This summary was prepared from contemporaneous, daily time records regularly prepared and

maintained by my firm.

6. The total number of hours expended on this litigation by my firm from case

inception through April 30, 2015 is 5315.42 hours. The total lodestar for my firm is

$3,175,725.14.

7. The hourly rates for the attorneys and professional support staff in my firm

included in Exhibit 2 are the usual and customary hourly rates charged by Stueve Siegel Hanson

LLP.

8. My firm has expended a total of $104,708.39 in unreimbursed costs and expenses

in connection with the prosecution of this litigation from case inception through April 30, 2015

(excluding paid assessments as discussed in ¶ 9). These costs and expenses are summarized in

the chart attached hereto as Exhibit 3. They were incurred on behalf of the Direct Purchaser

Class by my firm on a contingent basis, and have not been reimbursed. The expenses incurred in

this action are reflected on the books and records of my firm. These books and records are

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prepared from expense vouchers, check records and other source materials and represent an

accurate recordation of the expenses incurred.

9. Stueve Siegel Hanson LLP paid a total of $362,500.00 in assessments to the

litigation fund for the prosecution of this litigation against Defendants.

10. I have reviewed the time and expenses reported by my firm in this case which are

included in this declaration, and I affirm that they are true and accurate.

I declare under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct. Executed on this 8th day of June, 2015 at San Diego, California.

s/Jason S. Hartley___________________ JASON S. HARTLEY

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EXHIBIT 1

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Representing Corporate and Individual

Plaintiffs Nationwide in Complex Litigation

www.stuevesiegel.com

Kansas City 460 Nichols Road, Suite 200 Kansas City, Missouri 64112

(816) 714-7100 tel (816) 714-7101 fax

San Diego 550 West C Street, Suite 1750 San Diego, California 92101

(619) 400-5822 tel (619) 400-5832 fax

New York 1359 Broadway, Suite 2001 New York, New York 10018

(212) 999-7370 tel

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FIRM OVERVIEW

Stueve Siegel Hanson LLP was founded in 2001 by lawyers who formerly practiced

at large national law firms. The Firm now boasts more than thirty lawyers between its offices in Kansas City, San Diego and New York. The Firm is rated AV, and its lawyers have accumulated numerous local, regional, and national awards for their successes and dedication to the practice. Many of our lawyers formerly served as government lawyers or law clerks including several who served on the Eighth Circuit Court of Appeals, the Tenth Circuit Court of Appeals and federal district courts in Missouri and Kansas. Stueve Siegel Hanson represents plaintiffs and defendants in complex business, class action, securities, wage and hour, environmental, and product liability litigation and trials.

Since opening our doors in 2001, Stueve Siegel Hanson has obtained substantial

results in a wide range of complex commercial, class, and collective actions while serving as lead or co-lead counsel.

Class and Collective Actions

Obtaining up to $220 million in damages for all Missouri residents who purchased the

prescription pain reliever Vioxx before it was removed from the market;

Obtaining over $75 million in relief for purchasers of Hyundai vehicles for Hyundai’s overstatement of horsepower in vehicles;

Obtaining a $73 million settlement as one of the MDL lead counsel appointed in In re Bank of America Wage and Hour Employment Practice Litigation;

Obtaining $53.5 million in settlements between a class of direct purchasers of automotive lighting products and several manufacturers accused of participating in a wide-ranging price fixing scheme;

Obtaining over $44 million in restitution and $7.9 million in cash for dentists against Align Technology, Inc. in a nationwide deceptive trade practices case;

Obtaining $39.5 million in settlements from three refiners on behalf of adjacent home owners who were living above a large plume of gasoline leaked from the refineries and connecting pipelines;

Obtaining $35 million in relief for consumer fraud and antitrust claims brought on behalf of retail customers of pre-filled propane tanks;

Obtaining $33 million in relief for owners of Mitsubishi and Chrysler owners related to defective wheel rims;

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Obtaining $33 million in nationwide class action alleging price fixing for certain

polyurethanes in Urethanes antitrust case;

Obtaining $29.5 million in settlements for overdraft fees charged to customers from UMB Bank, Bank of Oklahoma and Intrust Bank;

Obtaining $25.4 million for purchasers of H&R Block’s Express IRA product related to allegedly false representations made during the sales presentation;

Obtaining a $7.7 million nationwide settlement after the Court certified a nationwide class of cable & wireless customers who had been overcharged PICC fees; and

Obtaining $7.2 million in relief for Sprint customers affected by Sprint’s practice of improperly charging “casual caller” rates. Stueve Siegel Hanson devotes a significant portion of its practice to representing

employees across the country in large wage and hour class and collective actions in various industries. Stueve Siegel Hanson has prosecuted more than 85 wage and hour class and collective actions throughout the country, including:

Obtaining in excess of $300 million in settlements of wage and hour claims on behalf

of employees, including in the financial services, pharmaceutical, and call center industries;

Obtaining a jury verdict in favor of workers at a Tyson Foods meatpacking facility in Holcomb, Kansas, for violation of federal and state labor and wage laws; and

Trying multiple wage and hour cases to decision in arbitrations, resulting in awards in favor of thousands of employees.

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Securities Actions

Stueve Siegel Hanson has obtained substantial results in a wide range of class and individual securities cases, including cases involving misrepresentations, suitability, and non-disclosure. Lawyers at the firm have prosecuted securities claims in a variety of state and federal courts and before the Securities and Exchange Commission, the Financial Industry Regulatory Authority (FINRA), and state regulatory agencies. The firm has acted as lead counsel in a number of cases alleging violations of the securities laws. Stueve Siegel Hanson is currently liaison counsel on behalf of a nationwide class asserting federal securities claims against Sprint Nextel. Stueve Siegel Hanson represented investors in connection with the collapse of the $330 billion auction rate securities market, including being named as lead class counsel in PSLRA cases against JP Morgan, Oppenheimer, E*Trade, UBS, Wachovia and Deutsche Bank – all pending in the United States District Court for the Southern District of New York. Stueve Siegel Hanson was also appointed as co-lead counsel in litigation against H&R Block in connection with the sale of its Express IRA product. In addition to leadership roles in class cases, Stueve Siegel Hanson has litigated a variety of unique securities claims on behalf of clients that do not fit the typical mold. The firm’s recent litigation against Brown Brothers Harriman and George K. Baum brought together over a dozen rural telephone companies to redress their failed investment in the $600 million Crossroads Wireless project. In those cases, the firm elected to pursue a strategy under state securities law, rather than the Security Exchange Acts. Stueve Siegel is currently and has historically represented states and other governmental entities. The firm understands the dynamics in representing governmental interests as many of our lawyers have worked in government before going into private practice. After returning to private practice, the attorneys at Stueve Siegel Hanson continue to be “go to” lawyers for public entities in the region. Below is a snapshot of a myriad of cases where the firm has directly represented governmental agencies in securities-related actions. National Credit Union Administration: Stueve Siegel Hanson currently represents the National Credit Union Administration, which is the federal agency that regulates credit unions. On behalf of NCUA, Stueve Siegel Hanson is prosecuting securities actions against Defendants including RBS Securities, Inc., Credit Suisse, Morgan Stanley, UBS and Wachovia, alleging federal securities causes of action related to the misleading sale of mortgage-backed securities to federal credit unions. Similar lawsuits against JP Morgan, Bear Stearns and WaMu were recently settled. KPERS: In September 2009, following a competitive RFP process, Stueve Siegel was the only local law firm selected by the Kansas Public Employees Retirement System (“KPERS”) Board of Directors to provide KPERS with securities monitoring and contingency litigation services. With its co-counsel, Stueve Siegel currently is pursuing high-stakes litigation on

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behalf of the pension fund. Kansas City Public School Retirement System: Stueve Siegel was recently retained by the Kansas City Public School Retirement System to provide it with securities monitoring and contingency litigation services. Jackson County, Missouri: In addition to its work in Kansas, Stueve Siegel is litigation counsel for Jackson County, Missouri, in the county’s class-action case against Mortgage Electronic Registration Systems, Inc. (“MERS”) and its affiliated members. In addition to this direct experience, Stueve Siegel frequently litigates cases involving interaction and coordination with federal and state agencies, the Securities and Exchange Commission and federal and state labor departments. The firm has worked alongside attorneys general from several states, including coordinating with the office of then-New York Attorney General Andrew Cuomo and Mississippi Attorney General Jim Hood.

Antitrust Litigation Since its founding more than a decade ago, antitrust and unfair competition litigation has been a core practice area for Stueve Siegel Hanson. Our attorneys have and continue to represent clients on a broad range of antitrust law claims including:

Price fixing Supply fixing Bid-rigging Monopolization Conspiracy to restrain trade Attempts to boycott Tying arrangements and Franchise, licensing and intellectual property claims involving antitrust issues

Stueve Siegel Hanson spends a significant amount of time investigating potential antitrust claims and advising clients on antitrust issues. These antitrust investigations have included work on behalf of individuals, small companies and some of the country’s largest corporations. Prior to undertaking the substantial time involved in an antitrust lawsuit, we want to ensure that our client fully understands the unique risks and costs associated with prosecuting an antitrust claim. It is not unusual that we work with our clients for many weeks and months to develop the factual bases needed for a complaint to successfully survive the inevitable motion to dismiss.

We pride ourselves on the thoroughness of our investigations. We believe that such investigations are essential to a client making a fully-informed decision on whether to proceed with a state or federal antitrust claim or whether there are other, more efficient ways to accomplish the client’s end goals.

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While Stueve Siegel has significant experience in class action antitrust cases, one of the most unique aspects about Stueve Siegel is its lengthy history of prosecuting antitrust litigation on behalf of individuals or companies. For example, in 2008, Stueve Siegel settled multi-million dollar antitrust claims brought on behalf of Heartland Spine & Specialty Hospital, a physician-owned hospital, against the largest managed care organizations (MCOs) and hospitals in the Kansas City area. The lawsuit alleged that the dominant hospital systems conspired amongst themselves and with the dominant MCOs to prevent Heartland from obtaining in-network provider contracts. This was one of the largest antitrust cases ever filed in the United States District Court for the District of Kansas and ultimately involved approximately 100 depositions and millions of pages of documents—all handled in-house by Stueve Siegel’s lawyers and staff. The lawsuit settled with all Defendants after the District Court denied defendants’ summary judgment motions. Below is a brief sample of Stueve Siegel’s current and recently resolved individual antitrust and unfair competitive cases, including:

Associated Wholesale Grocers, Inc., et al. v. United Egg Producers, et al. —

confidential settlements resolved litigation on behalf of Associated Wholesale Grocers, Inc., a multi-billion dollar grocery wholesaler, and local grocery stores in an antitrust lawsuit filed in Kansas state court against twenty egg producers and egg industry trade groups for artificial inflation of egg prices and supply fixing;

Associated Wholesale Grocers, Inc., v. United Potato Growers of America, Inc., et al. — representing Associated Wholesale Grocers, Inc. in an individual antitrust suit against the country’s largest potato growers and shippers alleging that these defendants fixed the price of fresh and processed potatoes;

Radon Sport, Inc. v. Sports Car Club of America et al. — represented Radon

Sport, Inc. in an antitrust action against several race cars manufacturers and the industry’s sanctioning body. The plaintiff alleged that the defendants had engaged in a long-running conspiracy to prevent them from entering the market for Formula Continental race cars;

Seaboard Corporation v. Marsh Inc. & American International Group —

represented Seaboard, a Fortune 500 Company, in litigation filed in Kansas state court involving anticompetitive bid-rigging conduct between Seaboard’s insurance broker and insurance companies. A confidential settlement was reached in 2012;

Formula One Licensing B.V. v. Purple Interactive Limited — represented a

London, England based defendant who countersued the sponsors of the licensing for Formula One in the Northern District of California for violating

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Sections 1 and 2 of the Sherman Act. The antitrust claims involved conspiracy in restraint of trade and illegal monopolization claims, all related to the operation, management, and internet presence of the Formula One World Championship. During the course of the litigation, Stueve Siegel deposed the key executives of Formula One Racing, including Bernie Ecclestone, the founder of Formula One. After successfully defeating a motion to dismiss and partial summary judgment motion, the case resulted in a confidential settlement only a few weeks from trial;

Global Jet v. Flight Safety International — prosecuted a Sherman Act Section

1 claim alleging conspiracy to restrain trade against a Berkshire Hathaway subsidiary in the Federal District Court for the Eastern District New York. The case resulted in a confidential settlement;

United States v. Smigel — Stueve Siegel obtained a not guilty verdict in the

United States District Court for the Southern District of Texas for the president of a metal building insulation company accused of criminal violations of the federal antitrust laws. The not guilty verdict came after a seven week jury trial and involved more than 50 government and defense witnesses; and

American Central v. Union Pacific Resources — Stueve Siegel secured a

favorable arbitration decision and trial court judgment in favor of Duke Energy Corporation in an antitrust case involving the natural gas gathering, processing and liquids pipeline industries.

Stueve Siegel’s current and recently resolved class action antitrust and unfair competition cases include:

In re: Aftermarket Automotive Lighting Products Antitrust Litigation —

appointed as Lead Counsel in a nationwide price fixing conspiracy class action in the United States District Court for the Central District of California. Settlements obtained for the Class total more than $53 million;

In re: Aftermarket Automotive Sheet Metal Parts Antitrust Litigation —

appointed as Lead Counsel in a nationwide price fixing conspiracy class action in the United States District Court for the Eastern District of Wisconsin;

In re Visa/MC Interchange Fee Antitrust Litigation — serve on the Executive

Committee for plaintiff merchants in this nationwide class action against Visa and Mastercard for conspiring to fix the interchange fee charged to merchants;

In re Korean Air Passenger Surcharge Antitrust Litigation — serve as

plaintiffs’ counsel in this nationwide class action against airlines that conspired to fix certain surcharges to passengers;

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In re: Pre-Filled Propane Tank Marketing & Sales Practices Litigation — appointed as Lead Counsel for multidistrict antitrust litigation in the United States District Court for the Western District of Missouri alleging Ferrellgas and AmeriGas conspired to reduce the fill levels of retail propane tanks. Stueve Siegel negotiated a $9 million class settlement with AmeriGas and a $25 million settlement with Ferrellgas;

Leiszler v. Align Technology, Inc. — appointed as Lead Counsel in a

nationwide unfair competition class action representing more than 22,000 dentists against Invisalign in the United States District Court for the Northern District of California. The settlement in this lawsuit gave a 100% recovery to the class, with a value of more than $50 million in cash and non-cash relief; and

In re Urethanes Antitrust Litigation — served as co-lead counsel for this

nationwide class action alleging price fixing for certain polyurethanes. The case settled for over $33 million after four years of litigation.

Success in prosecuting an antitrust case stems directly from the quality of the attorneys prosecuting these cases. Our attorneys are repeatedly recognized by their peers for their excellence in publications including Best Lawyers in America, Super Lawyers, Benchmark Plaintiffs, and Lawdragon Magazine. Our attorneys also uniquely bring extensive experience working with governmental agencies. Norman Siegel, one of Stueve Siegel’s founding partners, worked as an Assistant Attorney General for the State of Missouri under then Attorney General Jay Nixon, now Missouri Governor Jay Nixon.

Former Kansas Attorney General Steve Six joined Stueve Siegel’s litigation team after finishing his term as the 43rd Attorney General for the State of Kansas. In his role as the Kansas Attorney General, Steve was directly involved in investigative efforts into the potential impacts of two mergers: the merger between JBS and National Beef; and Verizon’s acquisition of Alltel. In investigating the impact these mergers would have on Kansas, Steve worked directly with the Antitrust Division of the Department of Justice in filing suit to block or modify both of the mergers.

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Commercial Litigation

In addition to the cases discussed above, Stueve Siegel Hanson has a strong history of

representing individuals and companies in commercial litigation in courts throughout the country, including:

Seaboard Corporation et al. v. Grindrod Limited et al. - A confidential settlement

was reached in this suit alleging fraud, breach of fiduciary duties, misappropriation of corporate opportunities, tortious interference and civil conspiracy.

Overlap, Inc. Software Litigation - Multiple confidential settlements for our client, a computer software developer, for claims alleging breach of software license, fraud

and negligent misrepresentation.

Kansas State University: Stueve Siegel has represented Kansas State University in

multi-million dollar contract litigation brought by the University against its former head football coach. The firm previously represented Kansas State University in

connection with a dispute with a global energy company’s performance under a complex energy agreement.

When your business is a victim of unfair and anticompetitive business tactics, taking legal action can be an effective way to protect your interests. Stueve Siegel Hanson has pursued and defended a broad variety of state and federal antitrust law cases in state and federal courts across the country. When we handle an antitrust case on behalf of a client, our goal is to win efficiently and effectively so that you can return to what really matters to you — pursuing the success of your business.

Stueve Siegel Hanson is proud of our long history of delivering results to our clients. We welcome the opportunity to present our qualifications in person, and we invite you to visit our offices to experience first-hand our resources and proven approach to high-stakes litigation.

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A TRIAL FIRM

Stueve Siegel Hanson prides itself in obtaining substantial results at trial. Some of our recent courtroom victories include:

An arbitration award in a $70 million bet the company Fraud and Deceptive Trade

Practices Act case for a family-owned franchiser headquartered in Phoenix, Arizona;

A $24 million jury verdict on behalf of independent contractor agents against State Farm in a breach of contract and tortious interference case;

A $7.1 million jury verdict against one of the country’s largest securities brokers, A.G. Edwards & Sons, in a breach of contract and fraud case;

A $3.5 million jury verdict and attorneys’ fee award against the world’s largest manufacturer of recreational boats in a fraud and breach of contract case;

A $1.6 million jury verdict against a major paint and coating supplier in a negligent misrepresentation case;

A $1.5 million award after trial of a fraudulent transfer claim on behalf of a bankruptcy trustee;

A jury verdict in favor of workers at a Tyson Foods meatpacking facility in Holcomb, Kansas for violation of federal and state labor and wage laws;

Multiple arbitration awards in favor of thousands of employees in arbitrations of wage and hour claims;

A $660,000 verdict in a fraud and breach of contract claim and a verdict in favor of our client in a breach of fiduciary counterclaim;

A defense verdict for a client defending a multi-million dollar tort claim; and

A defense verdict in a high-profile white collar criminal price fixing case following an eight week trial.

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REPRESENTATIVE CASES

Consumer Fraud Plubell v. Merck & Co., Case No. 04-CV-235817, Circuit Court of Jackson County, Missouri at Independence (consumer fraud class action alleging unlawful and unfair business practices under the Missouri Merchandising Practices Act; up to $220 million settlement approved). Powers Law Offices, P.C. v. Cable and Wireless USA, Inc., Case No. 99-CV-12007 EFH, United State District Court for the District of Massachusetts (consumer fraud case alleging Cable & Wireless overcharged PICC fees; $7.7 million settlement approved). Sadowski v. General Motors Corp., Case No. HG03091369, Superior Court for Alameda County, California (consumer protection case alleging that Dex-Cool degraded certain vehicles’ intake manifold gaskets and other engine salability components, and that in certain other vehicles, Dex-Cool formed a rusty sludge, clogging the vehicles’ cooling systems and causing vehicles to overheat; substantial monetary settlement approved in March 2008). In Re: H&R Block, Inc. Express IRA Marketing Litigation, Case No. 4:06-md-01786-RED, United States District Court for the Western District of Missouri (consumer protection case alleging H&R Block improperly marketed and sold its Express IRA product; $25.4 million class settlement approved May 2010). Hyundai Horsepower Litigation, Case No. 02CC00303, Superior Court for Orange County, California (consumer claims alleging Hyundai overstated horsepower ratings in more than 1 million vehicles sold in the United States over a 10 year period; settlement approved valued at between $75-$125 million). Parkinson v. Hyundai Motor America, Case No. 8:06-cv-345-AHS, United States District Court for the Central District of California (consumer protection case alleging Hyundai knowingly sold vehicles with defective flywheel systems; class settlement for reimbursement of repair expenses approved in April 2010). Tadken v. Mitsubishi Motor Sales of America, Daily v. Daimler Chrysler Motors Corp., Case No. 03CC00484, Circuit Court of Jackson County, Missouri (consumer protection case alleging Mitsubishi and Chrysler sold defective 17 inch rims installed on approximately 350,000 Daimler/Chrysler Avenger and Sebring Coupes and Mitsubishi Eclipse and Eclipse Spyder vehicles; approved settlement valued at $33 million). Cromwell v. Sprint Communications Co., LP, Case No. 99-2125, United States District Court for the District of Kansas (consumer fraud case alleging Sprint improperly charged casual caller rates for “direct-dialed” long-distance calls; $7.2 million settlement approved). In re: Underfilled Propane Tank Litigation, Case No. 4:09-md-02086-GAF, United States District Court for the Western District of Missouri (MDL consumer protection case alleging Ferrellgas and AmeriGas conspired to reduce the fill levels of retail propane tanks; $35 million in settlements approved).

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Lewin v. Volkswagen of America, Inc., Case No. L-3562-02, Superior Court of New Jersey, Atlantic County (consumer case against Volkswagen for defective window regulators installed on nearly 1 million vehicles; the value of the settlement including the replacement costs and extended warranty could exceed $50 million). Eaton, et. al v. Bank of Oklahoma, N.A., Case No. CJ-2010-05209, in the District Court in and For Tulsa County State of Oklahoma (case based on Bank of Oklahoma’s alleged unfair and deceptive overdraft fee practices; $19 million settlement). Allen et al. v. UMB Bank, N.A., Case No. 1016-CV34791, in the Circuit Court of Jackson County, Missouri at Kansas City (case based on UMB’s alleged unfair and deceptive overdraft fee practices; $7.8 million settlement). Molina et al. v. Intrust Bank, N.A., Case No. 10-CV-3686, in the Eighteenth Judicial District, District Court, Sedgwick County, Kansas (case based on Intrust Bank’s alleged unfair and deceptive overdraft fee practices; $2.75 million settlement). Environmental Henry, et al., v. The Dow Chemical Co., Case No. 03-47775-NZ, in the Circuit Court for Saginaw County, Michigan (environmental litigation case alleging Dow Chemical contaminated the Tittabawassee River in Saginaw County, Michigan lowering property values and interfering with the use and enjoyment of property; case pending). Hopkins v. Premcor, et al., Case No. 03-L-1053, Circuit Court of Madison County, Illinois (environmental class action litigation alleging several refiners caused a four-million-gallon underground gasoline plume in Hartford, Illinois; $39.5 million settlement approved). Unpaid Wages/FLSA Wass et al. v. NPC International, Inc., Case No. 09-CV-2254, United States District Court District of Kansas (class action representing pizza delivery drivers in violation of minimum wage laws; confidential settlement). Sanchez et al. v. Echosphere LLC, et al., Case No. 4:09-cv-00329, United States District Court Northern District of Oklahoma (collective action arbitration on behalf of customer service representatives for unpaid wages and overtime worked at call centers; arbitration win). In re: Bank of America Wage and Hour Employment Practices Litigation, MDL No. 2138, United States District Court for the District of Kansas (lead counsel in nationwide MDL wage and hour case alleging that Bank of America failed to pay for all time worked and to comply with state law; $73 million settlement reached in 2014). Qualls v. Sanofi-Aventis, Case No. 06-0435-CV-W-REL, United States District Court for the Western District of Missouri (FLSA case alleging Sanofi-Aventis failed to pay manufacturing and packaging operators for work duties pre- and post-shift; confidential settlement reached in 2006).

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Carson v. Bank of Blue Valley, Inc., Case No. 04-2507-CM, United States District Court District of Kansas (FLSA case seeking unpaid overtime pay on behalf of loan originators; settlement of more than $1 million reached in November 2005). McLean v. CenturyTel, et al., Case No. 3:08CV0865, United States District Court for the Western District of Louisiana (FLSA case alleging CenturyTel denied wages and overtime pay to its telephone-dedicated employees working in its call center facilities; confidential settlement reached in July 2009). West v. First Franklin Financial Corp., Case No. 06-2064-KHV/JPO, United States District Court District of Kansas (FLSA and California Rule 23 case against First Franklin Corporation on behalf of loan account managers for unpaid wages; settlement of $7.7 million reached in 2007). Carrell, et al. v. Gateway, Inc., Case No. 02-964-CV-W-DW, United States District Court for the Western District of Missouri (FLSA case against Gateway Computer that alleged Gateway failed to pay overtime to certain call center employees; confidential settlement). Stefaniak, et al. v. HSBC Bank USA Inc., Case No. 05 CV 6528, United States District Court for the Southern District of New York (FLSA and New York state law Rule 23 case alleging HSBC Bank was not compensating workers for the full amount of time spent on the job; $2.9 million settlement approved in July 2008). Teeter v. NCR Corporation, Case No. EDCV08-D0297, United States District Court for the Central District of California (FLSA and California Rule 23 case for NCR’s failure to accurately record all time worked and failure to pay earned wages and provide uninterrupted meal breaks to its customer engineers; settlement was reached in February 2009). Perry v. National City, Case No. 05-cv-891-DRH, United States District Court for the Southern District of Illinois (FLSA case representing current and former loan officers employed by National City Bank for unpaid overtime wages; settlement reached for $27.5 million in 2007). Brown, et al. v. National Bank of Kansas City, Case No. 04-2510-CM/JPO, United States District Court District of Kansas (FLSA case representing loan originators employed by National Bank of Kansas City for unpaid overtime; confidential settlement approved in January 2006). Davis, et al. v. Novastar Mortgage, Inc. Case No. 04-0956-CV-W-FJG, United States District Court for the Western District of Missouri (FLSA case against NovaStar Mortgage Company on behalf of loan officers for unpaid wages; court-approved settlement was reached in 2006). Johns v. Panera Bread Company et al., Case No.4:08CV1105 (JCH), United States District Court for the Eastern District of Missouri Eastern Division (FLSA case alleged Panera failed to pay its managerial employees for all overtime worked; settlement reached in February 2009). Horn, et al. v. Principal Financial Group, et al., Case No. 2:05-cv-2032 KHV-DJW, United States District Court District of Kansas (FLSA collection action against the Principal Residential

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Mortgage that alleged the bank failed to pay overtime to mortgage loan originators; a confidential settlement was reached in 2005). Garner v. Regis Corporation, Case No. 03-5037-CV-SW-SWH, United States District Court for the Western District of Missouri (FLSA case on behalf of approximately 1,300 current and former salon managers and stylists in a certified wage and hour collective action against Regis Corporation; Court-approved confidential settlement was reached in June 2006). Bruner, et al. v. Sprint Nextel Corporation et al., Case No. 07-cv-2164 KHV, United States District Court District of Kansas (FLSA collective action against Sprint seeking unpaid wages and overtime on behalf of call center representatives; settlement approved in 2009). Hernandez, et al. v. Texas Capital Bank, N.A., Case No. 07-00726-CV-W-ODS, United States District Court for the Western District of Missouri (FLSA case against Texas Capital Bank on behalf of loan officers and branch managers to recover unpaid wages and overtime pay; case was settled in 2008). Wells Fargo Overtime Litigation. As lead counsel, represented a class of loan originator plaintiffs in multidistrict wage and hour litigation consolidated in the Northern District of California. In Re Wells Fargo Home Mortgage Overtime Litigation, Case No. 06-1770-MHP (settled for $7.2 million in 2011). Also, lead counsel in separate multi-district wage and hour litigation pending in the Northern District of California involving a putative class of Wells Fargo loan processors. In Re Wells Fargo Loan Processor Overtime Pay Litigation, Case No. 1841 (MHP).

We are proud of our successes and our focus on results. Our mission is the same whether our clients are a class of employees or consumers, or Fortune 100 companies. More information about our commitment to results can be found on our website: www.stuevesiegel.com.

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* * *

Patrick J. Stueve has been recognized by his peers as one of the top commercial trial lawyers in the country for his efforts over the past 25 years. He has been named to The Best Lawyers® in America for Bet the Company, Antitrust and Commercial Litigation, Top 100 Super Lawyers in Kansas and Missouri, “Local Litigation Star” by Benchmark Plaintiffs, and “Best of the Bar” by the Kansas City Business Journal. Patrick has prosecuted claims in federal and state courts nationwide in the areas of antitrust, intellectual property, securities fraud and other commercial torts against some of the largest businesses in the world including Formula 1 Racing, Citigroup, United Health Care,

and AIG. Patrick has also successfully prosecuted several national and state wide class actions against global giants including Volkswagen, Merck & Co. and. His national practice includes privately-held companies like Heartland Spine & Specialty Hospital and Associated Wholesale Grocers as well as publicly traded Fortune 500 companies like Seaboard Corporation and Kawasaki. In addition to his law practice, Patrick serves on the Board of YMCA of the Rockies (Estes Park, CO), Alfred Friendly Press Partners (Washington D.C.), the KCMBA and LEAP.

* * *

Norman E. Siegel is a founding member of the firm. Over the last 20 years, Norm has gained a reputation as a stand-out trial lawyer both locally and nationally. He has successfully tried to verdict a wide range of cases including obtaining several multi-million dollar jury verdicts. Norm has also been recognized for obtaining some of the largest settlements in the country, successfully securing hundreds of millions of dollars for his clients over the course of his career.

Norm was born in Baltimore, Maryland. He received a degree in political science from Tufts University, and his J.D. from Washington University in St. Louis. At Washington University he served as Articles Editor of the Washington University Journal of Urban

Contemporary Law. Norm has been named to The Best Lawyers® in America, has been elected a Missouri Super Lawyer, and has been named “Best of the Bar” and "Kansas City Newsmaker" by the Kansas City Business Journal. Norm was also named to Lawdragon Magazine’s 500 Leading Plaintiffs’ Lawyers in America, and named a “Local Litigation Star” by Benchmark Plaintiffs. Norm is rated AV – the highest designation a lawyer can achieve from publisher Martindale-Hubbell. Prior to starting Stueve Siegel Hanson in 2001, Norm served as an Assistant Attorney General and as a partner at what is now Dentons.

Our Lawyers

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Our Lawyers George A. Hanson graduated with High Honors from Oberlin College with a B.A. in History. In 1992, George obtained his J.D., cum laude, from the University of Minnesota Law School. George is one of the region's leading commercial litigators and trial lawyers. George has been named "Best of the Bar" by the Kansas City Business Journal for ten years and has also been elected a Missouri Super Lawyer every year since 2006. George has been named a "Local Litigation Star" by Benchmark Plaintiffs and was recently selected by his peers for inclusion in The Best Lawyers® in America. Additionally, he was named the Best Lawyers’ 2014 Kansas City, MO – Class Actions - Plaintiffs “Lawyer of the Year.” George is rated AV - the highest designation a lawyer can achieve from publisher Martindale Hubbell.

George is an experienced commercial litigator and trial attorney. George has successfully tried many cases to judges and juries in both state and federal court, and has extensive experience representing clients in arbitration. In addition to trial work, George has developed an active appellate practice and has successfully argued numerous cases before state appellate courts in Missouri, Kansas and Illinois, and federal appellate courts in the Eighth, Ninth and Tenth Circuits.

* * *

Todd M. McGuire began his legal career in the litigation department at Sonnenschein Nath & Rosenthal (now known as Dentons), specializing in antitrust, white collar criminal defense and commercial litigation. In October 2001, Todd joined Stueve Siegel Hanson LLP and in January 2005, Todd was elected to the Firm’s partnership. Todd is an experienced commercial litigator and trial attorney. He has successfully represented clients in numerous jury trials in both federal and state court. Todd has also successfully represented clients involved in arbitration proceedings. In addition to trial work, Todd has successfully handled numerous appeals in both state and federal court. Todd is admitted to practice in federal and state courts in

Missouri and Kansas, as well as before the Supreme Court of the United States and United States Court of Appeals for the Seventh, Eighth and Tenth Circuits.

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Our Lawyers

Todd E. Hilton began his legal career in the Kansas City office and national headquarters of Lathrop & Gage, L.C., specializing in wrongful death and catastrophic injury cases as well as consumer protection litigation. In October 2001, Todd joined Stueve Siegel Hanson, LLP as an associate. In June 2006, Todd was elected to the Firm's partnership as an equity partner. He continues to grow his practice at the Firm and specializes in the areas of wrongful death and catastrophic injury litigation, class action litigation, and complex business litigation. Todd has spent his legal career serving as trial and appellate counsel for individuals, as well as both large and small companies, in a wide

array of wrongful death and catastrophic injury litigation, product defect litigation, class action litigation, complex business litigation and environmental litigation. He has represented clients in state and federal courts as well as AAA arbitrations throughout the country - including in the states of Arizona, Arkansas, California, Colorado, Florida, Illinois, Kansas, Louisiana, Michigan, Missouri, New Jersey, New York, Oklahoma, Pennsylvania, Texas and Washington, D.C. Todd has also served in various capacities as co-lead counsel in complex cases and served on various Plaintiffs' Steering Committees.

* * *

Rachel E. Schwartz has significant litigation experience in courts across the country, where her practice focuses on antitrust and securities litigation. As a result of her work, Rachel has been repeatedly recognized as one of the "Local Litigation Stars" for the State of Missouri by Benchmark Plaintiffs and recognized by her peers in Super Lawyers as a Rising Star in 2011 and 2012 and a Missouri and Kansas Super Lawyer in 2013 and 2014. Most recently, Rachel was selected for inclusion in The Best Lawyers® in America 2015 in the field of Litigation-Securities.

Rachel was born in Illinois and raised in Lawrence, Kansas. Rachel received her B.A. with honors in Political Science, Economics and

American Studies from the University of Kansas, where she was a member of Phi Beta Kappa and Mortar Board. She received her J.D. from the University of Michigan Law School, where she was an Associate Editor of the University of Michigan Journal of Law Reform. After practicing law in Dallas for three years, Rachel joined Stueve Siegel Hanson LLP in 2004 and was elected to the Firm's partnership as an equity partner in 2008.

Rachel currently serves on the Bench-Bar Committee for the United States District Court for the District of Kansas. In August 2013, she was appointed to the Merit Selection Panel for the Kansas City Magistrate Judge vacancy in the District of Kansas.

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Our Lawyers

Steve Six is an experienced trial attorney and has successfully tried complex cases before juries in state and federal court. In addition to his trial practice, Steve has maintained an active appellate practice and has successfully argued cases before state appellate courts in Kansas and Missouri, the federal appellate courts and before the United States Supreme Court. Steve has tried cases to verdict in a wide variety of areas, including product liability, professional liability, commercial cases and consumer fraud as well as prosecuting criminal cases. Steve has litigated cases before the Judicial Panel on Multidistrict Litigation and has significant experience in multi-district litigation. In addition to his litigation work, Steve serves as a mediator in a variety of matters including complex commercial, antitrust, and tort cases.

Steve received his J.D. from University of Kansas School of Law where he was a member of the Order of the Coif and a Rice Scholar. Steve joined Stueve Siegel Hanson following his term as the 43rd Attorney General of Kansas. As Attorney General, Steve successfully represented the State of Kansas in complex cases in various areas including healthcare, antitrust, environmental resources and consumer protection. Prior to becoming Attorney General, Steve served as a district court judge in Kansas. Before taking the bench, Stueve successfully prosecuted jury trials in both Kansas and Missouri state courts and in federal court.

* * *

Jason Hartley’s practice includes class action litigation, antitrust and unfair competition, and music law. He is involved in all aspects of civil litigation and has handled cases in both federal and state courts, in litigation and at trial. For the past several years, his practice has involved primarily antitrust and consumer class actions, often representing the largest plaintiff class members in nationwide antitrust actions. Jason has successfully represented plaintiffs in federal Section 1 (conspiracy) and Section 2 (monopoly) Sherman Act cases and in state law actions alleging unfair business practices, false advertising, warranty and Proposition 65 violations, among other claims. He has

served as lead counsel and in senior litigation roles in numerous class actions, which have collectively recovered billions of dollars for plaintiffs.

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Our Lawyers

Barrett Vahle represents businesses and individual clients in a broad range of litigation matters, from contract and antitrust disputes, to consumer and employment class actions. He was named a Missouri and Kansas Super Lawyer in 2013 and 2014. Before joining Stueve Siegel Hanson in 2009, Barrett practiced in the Kansas City office of Sonnenshein Nath & Rosenthal LLP (now known as Dentons), one of the largest law firms in the country. At Sonnenschein, Barrett concentrated his practice in business litigation, trade secret and non-compete litigation, white collar criminal defense, and appellate practice. In 2004, Barrett obtained his J.D., with highest honors (graduating

first in his class) from the University of Missouri − Columbia. During law school, he was Editor-in-Chief of the Missouri Law Review, and received the Judge Shepard Barclay Prize for the graduating law student "who has attained the highest standing in scholarship and moral leadership." After law school, Barrett was a law clerk for the Honorable Duane Benton of the United States Court of Appeals for the Eighth Circuit, and then for Judge Dean Whipple of the United States District Court for the Western District of Missouri.

* * *

Bradley Wilders received both his undergraduate and law degrees from the University of Missouri - Columbia. He began his professional legal employment as a law clerk for the Honorable John R. Gibson of the United States Court of Appeals for the Eighth Circuit. Brad had the rare opportunity to work on cases in five of the eleven federal circuit courts of appeals, including the First, Second, Sixth, Eighth, and Ninth.

Following his clerkship, Brad was an associate with the law firm Sidley Austin LLP in Chicago, Illinois. At Sidley, he practiced intellectual property litigation, where he defended one of the world's largest computer companies against multiple accusations of patent infringement. His cases included both software and hardware patent

claims.

Brad joined Stueve Siegel Hanson as an associate in 2009 and was named Partner in 2015. He practices in patent, copyright, trademark, and antitrust litigation.

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Our Lawyers

Andrew Funk received his undergraduate degree from Princeton University, and his J.D. from the University of Missouri-Columbia School of Law, where he was Editor-in-Chief of the Missouri Law Review, and received the Top Oralist award in the Board of Advocates Fall Moot Court Competition, as judged by members of the Missouri Supreme Court. Prior to law school, Andrew worked as an executive and legislative assistant in the office of U.S. Representative Dennis Moore in Washington, D.C. and was a law clerk in the Missouri Attorney General's office in the Criminal Appellate Division.

Andrew primarily practices commercial litigation, concentrating on startup businesses and partnership disputes. Andrew also has experience in wage & hour and personal injury cases. Andrew's litigation experience covers state and federal courts throughout the United States.

Before joining Stueve Siegel Hanson in 2011, Andrew practiced at Seyferth Blumenthal & Harris and Shook Hardy & Bacon in Kansas City.

* * *

Jeff Scurlock represents businesses and individual clients in a range of litigation matters from antitrust disputes to consumer and employment class actions. Jeff also provides research, writing and discovery support in a wide range of cases. This includes writing briefs and arguments to the court and drafting complex analyses on critical legal issues.

Jeff has sixteen years' experience in the practice of law. Before joining Stueve Siegel Hanson in 2012, Jeff practiced law at the The Henning Law Firm. He also served as a law clerk for the Honorable Thomas H. Newton, Missouri Court of Appeals. Additionally, Jeff practiced law for several years with Shook, Hardy & Bacon LLP in Kansas City,

where he focused on complex products liability actions in state and federal courts across the United States.

Jeff received his J.D. from the University of Missouri-Kansas City School of Law, where he graduated first in his class, with distinction. He was a member of the Law Review and earned 16 CALI awards for academic excellence. Jeff is also a member of Phi Beta Kappa.

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Our Lawyers

Lindsay Todd Perkins is an experienced legal writer and researcher, having honed her skills in these areas since being admitted to the bar. Lindsay collaborates with attorneys on a variety of matters on behalf of the firm's clients, developing strategies and arguments for briefings to the court and interpreting laws, rulings and regulations.

Lindsay earned her Juris Doctor from the University of Missouri at Kansas City School of Law, graduating first in her class. She was the Editor-in-Chief of the UMKC Law Review, and was a member of the National Moot Court team. Lindsay received an MBA from the University of Central Missouri and a bachelor’s degree in psychology from Avila University. She is admitted to the bar in Missouri and

Kansas.

After law school, Lindsay served as a law clerk for the Honorable Duane Benton of the Eighth Circuit Court of Appeals and the Honorable Ortrie D. Smith, District Court judge for the Western District of Missouri. Following her clerkships, Lindsay practiced commercial and employment litigation at the law firm of Spencer Fane Britt & Browne LLP.

* * *

Ryan D. O’Dell is an experienced trial attorney and litigator representing plaintiffs and defendants in federal and state courts and in all forms of alternative dispute resolution.

Ryan was raised and lives in San Diego, California, where he practices throughout the country from the Firm’s San Diego office.

Before joining Stueve Siegel Hanson in 2013, Ryan practiced for nearly 15 years at nationally recognized law firms located in Kansas City, Missouri. He has represented clients ranging from individuals and small businesses to Fortune 500 companies. The scope of his practice includes complex commercial, construction, insurance coverage, real

estate, surety, product liability, wage and hour, and employment litigation matters.

Ryan is admitted to practice in state and federal courts in California, Kansas, and Missouri.

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Our Lawyers

Jason M. Lindner has a practice that includes litigation of antitrust, unfair competition, complex business, California wage and hour, Fair Labor Standards Act, and other general class action litigation. He has been involved in all aspects of civil litigation in both federal and state courts.

Jason has successfully represented plaintiffs in federal Section 1 (Conspiracy) and Section 2 (Monopoly) Sherman Act cases and in state law actions alleging unfair business practices. He has also represented classes of plaintiff employees under both the FLSA and under California State wage and hour statutes. He has served as lead counsel and in senior litigation roles in numerous class actions, which

have collectively recovered billions of dollars for plaintiffs.

* * *

Darren T. Kaplan received his B.A. degree in political science from Syracuse University and his J.D. from Hofstra University School of Law. He is admitted to the state bars of Connecticut, Georgia and New York. Darren was elected a New York Metro Super Lawyer for the last four years and is rated AV – the highest designation a lawyer can achieve from publisher Martindale-Hubbell.

Darren joined Stueve Siegel Hanson in 2014. He was formerly a partner at Chitwood Harley Harnes LLP and Harnes Keller LLP in New York, New York where he litigated a number of cases in the areas of corporate governance, investor rights, securities fraud and consumer protection.

In addition to representing shareholders in derivative and class action litigation, Darren also focuses on representing institutional investors in litigation and arbitration of significant transactional claims and has written extensively on the legal issues surrounding hedge funds and private equity funds as well as structured asset-backed securities, derivatives, and swaps. In 2011, Darren was a featured speaker at the American Conference Institute's National Summit on the Future of Fiduciary Responsibility.

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Our Lawyers

David Hickey represents businesses in a broad range of disputes, including antitrust claims, breach of contract, breach of fiduciary duty, and intellectual property claims. David also represents individual clients in a variety of matters, including violations of wage and hour laws and consumer protection laws.

David was born in Kansas City, Missouri and raised primarily in Overland Park, Kansas. David received his J.D. from the University of Kansas School of Law in 2009. During law school, David was selected to serve as Staff Editor of the Kansas Journal of Law & Public Policy and as a member of the University of Kansas Moot Court Council. David also interned as a clerk for the Honorable David

J. Waxse, U.S. Magistrate Judge for the U.S. District Court, District of Kansas. In 2006, David graduated with a B.S. in Mechanical Engineering from the University of Kansas.

After law school, David practiced in Overland Park, Kansas where he represented individuals and small businesses in a variety of matters, including contract disputes, personal injuries, and violations of consumer protection laws. In 2010, David joined Stueve Siegel Hanson LLP, where he primarily handles complex business litigation.

* * *

Jennie Carter provides research, writing and discovery support to antitrust, class action, and wage and hour litigations. Jennie routinely adds value to our clients’ cases by researching and writing on complex legal issues. She also analyzes large volumes of discovery material to expose key evidence for our clients.

Prior to joining Stueve Siegel Hanson in 2010, Jennie served as a law clerk for the Honorable Carlos Murguia in the U.S. District Court for the District of Kansas. Following her clerkship, Jennie practiced in the financial services department at the law firm of Polsinelli.

Jennie received both her undergraduate and law degrees from the University of Kansas. In law school, Jennie served as the Kansas Law Review Articles Editor, participated in the Judicial Clerkship Clinic, and volunteered for the Volunteer Income Tax Assistance program. She is admitted to the bar in Missouri and Kansas.

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Our Lawyers

Stephanie Walters received her J.D. from the University of Missouri-Kansas City School of Law in 2007. During law school, she served as a Staff Editor of the UMKC Matrimonial Lawyer Law Journal, Executive Vice President of the Intellectual Property Law Society, and was a member of the UMKC School of Law Faculty Appointment Committee. Stephanie received an MBA from Webster University and a bachelor's degree in education from Missouri Western State University.

Stephanie joined Stueve Siegel Hanson as a staff attorney in April 2011. She became the firm's eDiscovery and Litigation Support counsel in May 2012. Stephanie counsels attorneys on electronic discovery

issues including preservation, collection, search term negotiation, document review, ESI production, eDiscovery software, and forms of production. She has managed large scale document preservation, custodian interviews, ESI collection, review and production. In addition to managing the firm’s ESI issues, Stephanie frequently trains attorneys to leverage review software for increased efficiency of review and for advanced searching functionality. She has experience using Summation, Concordance, Relativity, Kaleidoscope and CasePoint review software.

* * *

Lauren Wolf joined Stueve Siegel Hanson in 2011 where her practice includes class actions, antitrust litigation, and wage and hour litigation. Additionally, Lauren is responsible for all aspects of settlement administration and claims handling on behalf of the firm's clients in class action matters.

Lauren received her J.D. from the University Of Iowa College Of Law in 2010. During law school, Lauren served as a student judge on the Moot Court Board. Lauren also worked as a research assistant for Professor Herbert Hovenkamp, where she participated in research on antitrust and intellectual property. She graduated from Kansas State University with a degree in Psychology.

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Our Lawyers

James Vaglio received his bachelor’s degree in political science with highest distinction and his M.B.A. with distinction from the University of Kansas, where he was a member of Phi Beta Kappa. He graduated from the University of Iowa College of Law in 2011. While in law school, James served as a legal intern in the University of Iowa Clinical Law Program and assisted California’s Habeas Corpus Resource Center in post-conviction capital defense litigation.

James joined Stueve Siegel Hanson in 2012 where his practice focuses on antitrust litigation and class actions.

* * *

Larkin Walsh has eight years of experience advising the judiciary, in state and federal court, at both the trial and appellate court levels. Before joining Stueve Siegel Hanson as Of Counsel in 2013, Larkin served as law clerk to the Honorable Carlos Murguia, Judge for the U.S. District Court, District of Kansas, and as a research attorney for Justice Carol Beier of the Kansas Supreme Court.

Larkin brings her expertise as a legal writer and researcher to the firm, structuring arguments and crafting briefs for courts across the country in the variety of cases the firm handles. She enjoys the process of weaving facts and law together into a compelling story. In the course of her career, she has reviewed thousands of briefs across a wide

variety of practice areas, and has drafted complex analyses on a variety of critical legal questions. Larkin is adept at researching complex legal issues and preparing no-nonsense motions designed to pinpoint the relevant issues for the Court and advocate for a favorable ruling.

Larkin earned her J.D. from the University of Kansas School of Law, where she was a University Merit Scholar and served as the articles editor for the Kansas Journal of Law & Public Policy, and co-managing editor of the law school's newspaper, The Brief-Brief. She received her undergraduate degrees in English and Studio Art, cum laude, from Southern Methodist University. She is admitted to the bar in Missouri and Kansas.

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Our Lawyers

Austin Moore received his B.A. in Political Science from the University of Mississippi, where he graduated summa cum laude and was elected as a member of Phi Beta Kappa and Phi Kappa Phi. In 2011, Austin obtained his J.D. from the Washington University School of Law in St. Louis where he was an associate editor and published member of the Washington University Journal of Law & Policy and the 2011 recipient of the Mary Collier Hitchcock Prize, awarded to one student annually for outstanding legal writing. Before joining Stueve Siegel Hanson in 2013, Austin was in private practice in St. Louis, Missouri, where he handled a number of complex commercial cases and maintained an active state and federal appellate

practice. Austin focuses his practice on complex business litigation including antitrust, class action and multi-district litigation. Austin has significant experience prosecuting consumer class action claims in the emerging area of data breach litigation, as well as litigating complex commercial disputes under the Sherman Act, Lanham Act, RICO Act, federal securities laws, and state antitrust and consumer protection statutes.

* * *

Lisa R. Joyce focuses her practice on multidistrict litigation. She has investigated over 1,000 mass tort claims, analyzes medical records for evidence of target injuries, interviews clients and drafts injury narratives. After settlement, Lisa resolves health care liens asserted by Medicare, Medicaid, and private health insurance providers.

Lisa earned her Juris Doctor from the University of Missouri at Kansas City School of Law where she was winner of the 2000 Kansas City Federal Estate Planning Society’s Essay Prize and was a staff member of the UMKC Law Review. Lisa received a bachelor’s degree in English literature from the University of Kansas. She is admitted to the bar in Missouri and Kansas.

Lisa has been a practicing attorney for 15 years.

.

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Our Lawyers

Lauren Luhrs received her J.D. from the University of Kansas School of Law in 2013. During law school, Lauren was the Managing Editor of the Kansas Law Review, a Raymond F. Rice Foundation Scholar, Dean’s Fellow, and a member of the Dean’s Student Advisory Board. During her third year of law school, Lauren served as a judicial extern to the Honorable Carlos Murguia, Judge for the U.S. District Court for the District of Kansas.

Lauren received her undergraduate degree from Kansas State University, summa cum laude, in 2008. While at K-State, Lauren was involved in a variety of student leadership organizations, including Blue Key, Mortar Board, and Student Alumni Board.

Lauren joined Stueve Siegel Hanson in 2013 where her practice includes class actions, antitrust litigation, and wage and hour litigation.

* * *

Sean Cooper received his J.D. from the University of Kansas School of Law in 2013. During law school, Sean was an Associate Editor of the Kansas Law Review and won CALI Excellence for the future Awards in KU’s Immigration and Asylum Clinic and International Human Rights Law. Before law school, Sean received B.A. in English from Truman State University and graduated Summa Cum Laude. He also received his M.A. in English from Truman State. After receiving his M.A., Sean taught English as a second language in Bangkok, Thailand.

Sean joined Stueve Siegel Hanson in 2013 where his practice includes class actions, antitrust litigation, and wage and hour litigation.

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Our Lawyers

Crystal R. Cook received her J.D. from the University of Kansas School of Law in 2013. During law school, Crystal was the Staff Editor and Co-Director of Alumni & Internal Relations of the Kansas Journal of Law & Public Policy and a recipient of the CALI Excellence for the Future Award in Construction Law & Litigation. Throughout law school, Crystal clerked at the Kansas Department of Transportation in the Office of Chief Counsel.

Prior to law school, Crystal worked in Washington, D.C. for over three years as an Executive Assistant at the White House and then as a Legislative Assistant at an international law firm providing legislative and government relations assistance to numerous clients on

environmental, transportation, health care, and educational issues.

Crystal received her undergraduate degree from Fort Hays State University, cum laude, in 2007, while earning a double major in Political Science and History.

Crystal joined Stueve Siegel Hanson in 2013 where her practice includes class actions, antitrust litigation, and wage and hour litigation.

* * *

Abby E. McClellan received her J.D. from the University of Missouri – Kansas City (UMKC) School of Law in 2013. She received the CALI award for highest grade in Civil Procedure.

Abby received her undergraduate degree from Drury University, summa cum laude, in 2008, with a Bachelor of Arts in Elementary Education and a minor in Global Studies. Abby also studied International Law at Regents College in London and with the UMKC School of Law Ireland Program.

Abby joined Stueve Siegel Hanson in 2014 where her practice includes class actions, antitrust litigation, and wage and hour litigation.

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Our Lawyers

Ethan M. Lange has been recognized by his peers as a go-to litigator. He was named by Super Lawyers as a “Rising Star” in both 2014 and 2015. He has successful first chair federal jury trial experience, among his other achievements at trial. In addition to his trial exposure, he has handled numerous hearings, depositions, mediations, and motions. He is experienced at all stages of litigation and is equipped to meet his clients’ goals and objectives. Ethan is known for his hard work ethic and representing his clients vigorously and ethically.

Ethan received his J.D., magna cum laude, from Baylor Law School, where he was the Editor-in-Chief of the Baylor Law Review. He was the Number One Speaker in the Dawson & Sodd Moot Court Tournament and was selected for membership in the Order of the Barristers. After law school, Ethan was a law clerk for the Honorable Ed Kinkeade of the United States District Court for the Northern District of Texas, Dallas Division. Before joining Stueve Siegel in 2015, Ethan practiced in the Dallas office of Locke Lord LLP. Ethan’s practice is concentrated in business litigation and arbitration.

* * *

Daniel Shaw received his J.D. from the University of Kansas School of Law in 2013. During law school, Danny clerked at the Kansas Department of Commerce in the Office of Chief Counsel focusing on the Department’s Rules and Regulations initiative.

Prior to joining Stueve Siegel Hanson in 2015, Danny worked as an associate for a Kansas City-based firm specializing in consumer protection with an emphasis on the KCPA, MMPA and FDCPA statutes.

Danny received a Bachelor of Science in Finance from the University of San Diego in 2009.

Danny’s practice includes class actions, antitrust litigation, and wage and hour litigation, as well as case investigation research.

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More detailed biographies are available online at

www.stuevesiegel.com

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The Right Contingency.

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EXHIBIT 2

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Name TitleYear of Bar Admission Hours

HistoricalRate/Hr. Lodestar

AttorneysJason S. Hartley Partner 1997 1,169.40 $700 818,580.00$

Jason S. Hartley Partner 1997 1,798.70 $725 1,304,057.50$

Jason M. Lindner Associate 2000 1,218.60 $550 670,230.00$

Eric L. Dirks Partner 2003 89.80 $500 44,900.00$

Andrew W. Funk Associate 2007 2.10 $425 892.50$

Trent Tang Associate 2007 443.10 $250 110,775.00$

Edward E. Keenan Associate 2010 23.82 $252 6,002.64$

Christina M. Lucio Associate 2007 2.80 $350 980.00$

Ryan D. O'Dell Associate 2000 12.50 $575 7,187.50$

Norman E. Siegel Partner 1993 1.40 $725 1,015.00$

Patrick Stueve Partner 1988 166.30 $725 120,567.50$

James C. Vaglio Associate 2011 16.60 $350 5,810.00$

Barrett J. Vahle Partner 2004 1.00 $550 550.00$

Stephanie A. Walters Associate 2007 6.20 $400 2,480.00$

Total Attorney Time 4,952.32 3,094,027.64$

Non-Attorneys

Tina J. Glover Paralegal 360.60 $225 81,135.00$

April J. Davis Paralegal 2.50 $225 562.50$

-$

-$

-$ Total Non-Attorney Time 363.10 81,697.50$

TOTALS 5,315.42 3,175,725.14$

EXHIBIT 2

Stueve Siegel Hanson LLPTime and Lodestar Summary

Case Inception through April 30, 2015

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EXHIBIT 3

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Disbursements TotalComputer Research 11,670.20$ Court Fees 943.45$ Court Reporter -$ Food and Beverage (see travel below) -$ Photocopying - Inhouse 1,133.60$ Photocopying - Commercial 96.22$ Postage/Express Delivery/Messenger 1,583.42$ Outside Professional Services 27,423.75$ Telephone/Facsimile 2,769.34$ Travel (Air, Ground Travel, Meals, Lodging, etc.) 56,049.96$ Witness/Service Fees 2,799.45$ Misc. (professional subscriptions and investigative resources) 239.00$ TOTAL 104,708.39$

Assessment Payments to the Litigation Fund $ 362,500.00

EXHIBIT 3

Stueve Siegel Hanson LLPExpense Summary

Case Inception through April 30, 2015

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