1 DECLARATION OF CHRISTOPHER J. WILLIAMS I, Christopher J ...

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DECLARATION OF CHRISTOPHER J. WILLIAMS

I, Christopher J. Williams, under penalty of perjury, state based on personal knowledge

that the following facts are true and correct:

1. I am over the age of 21 years.

2. I currently reside in Chicago, Illinois.

3. I am an attorney and the principal of Workers’ Law Office, PC (“WLO”).

4. I am the lead attorney in the matter of Lucas et al. v. Gold Standard Baking, Inc.

et al., Case No. 13 C 1524.

5. Prior to being admitted to practice law, I worked as a teacher in the Chicago

Public Schools and the City Colleges of Chicago from approximately 1984 to approximately

1994. From approximately 1989 through 1993, I served as a union officer and president of

American Federation of State, County and Municipal Employees (“AFSCME”) Local 3506,

representing teachers in the Adult Learning Skills Program at the City Colleges of Chicago. This

program encompassed pre-collegiate classes such as alternative high school, GED, Literacy and

English as a Second Language. Because this program largely served low-income and immigrant

communities, the City Colleges placed teachers in over 350 community-based organizations,

such as churches, schools, union halls, non-profit service organizations, community advocacy

organizations, health clinics, among others. As president of the union of teachers, I visited each

of these 350 plus community organizations. I developed relationships with many of these

community organizations that continue to exist today.

6. From approximately 1994 through 1999, I was worked as an Assistant Director of

Organizing for AFSCME Council 31 of Illinois and as Director of Organizing for the Service

Employees International Union (“SEIU”) Local 73 where I supervised a staff of twelve

Case: 1:13-cv-01524 Document #: 305-6 Filed: 01/09/15 of 13 PageID #:5771

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employees. During this period, I developed a strong understanding of workplace rights and

developed relationships with staff of many unions in and around Chicago that continue to this

day.

7. From approximately the end of 1999 through 2000, I served as the Director of the

Chicago Workers’ Center (“CWC”), a non-profit organization, providing worker’s rights

trainings and advocating for low wage immigrant workers. I also served as the CWC’s

representative to the Chicago Area Workers’ Rights Initiative (“CAWRI”), a taskforce of

community organizations serving at-risk communities working with governmental enforcement

agencies such as the EEOC, OSHA, and the U.S. and Illinois Departments of Labor. During this

period, I developed relationships with many community-based advocacy organizations that

continue to exist today.

8. I was admitted to the Illinois Bar and the General Bar of the U.S. District Court

for the Northern District of Illinois in 2004. I am also admitted to the Trial Bar in the Northern

District.

9. After being admitted to the Illinois 2004, I was one of the founders of a non-profit

legal service organization, Working Hands Legal Clinic, which provides assistance for low-

income Illinois residents (defined as earning 150% or below of the poverty level) in the area of

employment law. I served as the Executive Director of the Working Hands Legal Clinic through

June 30, 2011. During the period of my tenure as Director, Working Hands Legal Clinic assisted

in recovering over $5,000,000 in owed wages on behalf of low wage Illinois residents by

working with the Illinois and federal Departments of Labor as well as working with a network of

attorneys to litigate claims. During my tenure at WHLC, WHLC’s work was recognized and

funded by the Chicago Bar Foundation, the Illinois Equal Justice Foundation and the Lawyers’


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Trust Fund of Illinois, among other foundations. I developed relationships with many

community-based non-profit organizations, legal services organizations, consulates of foreign

governments and private attorneys which continue to exist today.

10. As Director of the WHLC, I served as legal advisor to the sponsors in the Illinois

Senate of the 2006 amendments to the Illinois Day and Temporary Labor Services Act

(“IDTLSA”) and of the 2011 amendments to the Illinois Wage Payment and Collection Act

(“IWPCA”) and worked with the Mexican American Legal Defense and Education Fund

(“MALDEF”) and the National Employment Law Project (“NELP”) in taking primary

responsibility for drafting the legislative language of these two amendments. From 2009 through

2011, I served as a member of a task force with the Illinois Department of Labor and the Office

of the Attorney General of Illinois to examine the problem of wage theft in Illinois which

resulted in the 2011 amendments to the IWPCA and the Illinois Department of Labor’s

administrative procedures in enforcing this law.

11. My work in the area of employment law, particularly for low-income and

immigrant workers, is well-known in both the legal community and the advocacy community. I

have served as an expert panelist at continuing legal education seminars sponsored by the

American Bar Association, the Chicago Bar Association, Illinois Legal Aid Online, the National

Employment Lawyers’ Association, the Illinois Employment Lawyers’ Association, the National

Employment Law Project, the AFL-CIO Lawyers’ Coordinating Committee, Chicago-Kent

College of Law, the DePaul University College of Law, among others. In 2011, I was awarded

the Honorable Abraham Lincoln Marovitz Public Interest Law Award by Chicago-Kent College

of Law. I currently teach a course entitled “Legal Issues Affecting Low Wage Workers” at

Chicago-Kent College of Law.


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12. Since being admitted to the Illinois and Federal Bar, I and the other attorneys of

WLO have conducted over a thousand “Know Your Rights” trainings at various health clinics,

schools, foreign consulates, unions and other worker advocacy organizations, churches, social

service organizations and other community-based organizations. At these “Know Your Rights”

trainings, WLO attorneys, including myself, typically present information in the form of Group

Attachment 1. As a result of these “Know Your Rights” presentations, the attorneys of WLO

have been contacted by hundreds of workers as a result of these presentations and have received

hundreds of referrals from the organizations sponsoring the presentations. Often, I and other

WLO attorneys conduct free legal advice clinics immediately after such presentations. WLO

sometimes takes such cases on a pro bono basis and sometimes on a contingency fee basis.

13. Since being admitted to the Illinois and Federal Bar, I have been lead counsel or

co-counseled in over 300 employment law cases filed in the Northern District of Illinois and the

Circuit Court of Cook County, the vast majority of which have been cases arising under the Fair

Credit Reporting Act ("FCRA"); Title VII of the Civil Rights Act of 1964, as amended, (“Title

VII”); the Civil Rights Act of 1866, as amended, 42 U.S.C. §1981 (“Section §1981”); the Fair

Labor Standards Act (“FLSA”); the Illinois Minimum Wage Law (“IMWL”), the Illinois Wage

Payment and Collection Act (“IWPCA”); and the Illinois Day and Temporary Labor Services

Act (“IDTLSA”). Over thirty of these cases have involved complex class action litigation arising

under the FCRA, Title VII, Section 1981, the IMWL, the IWPCA or the IDTLSA and/or have

proceeded as class collective actions arising under §216(b) of the FLSA. Our firm also assists

low-income people with unemployment claims and expungement of criminal records on a pro

bono basis.

14. I have been appointed class counsel by courts in the Northern District of Illinois


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and the Circuit Court of Cook County in twenty complex class action matters. A list of the cases

in which I was appointed by the Court as class counsel is attached hereto as Attachment 2.

15. In or about late November of 2014, I authorized WLO to mail out approximately

4,500 postcard advertisement postcards, in the form attached to Plaintiffs’ Response as Exhibit

A, to six postal routes in the North Chicago and Waukegan area, Illinois area. The postal routes

were all no less than 50 miles north of MVP’s Cicero branch office. No more postcards in the

form of Exhibit A have been mailed since this initial mailing.

16. Since the initial mailing, WLO has received calls from over two dozen residents

of Waukegan and North Chicago in Lake County, Illinois. Some of these individuals have

worked at different branch offices of the defendant staffing agencies identified in the postcard

advertisement than are at issue in the instant litigation, and others have worked for different

staffing agencies altogether.

17. As expected, none of the individuals who have contacted WLO in response to the

postcard advertisement have ever worked at any of the branch offices of the defendant staffing

agencies involved in any of the cases identified in the postcard advertisement, including MVP’s

Cicero branch office.

18. I am not suffering any impediments and am competent to testify to all of the

foregoing.

I declared under penalty of perjury that the foregoing is true and correct.

Dated: January 9, 2015

s/Christopher J. Williams

Christopher J. Williams

Workers’ Law Office, PC

401 S. LaSalle Street, Suite 1400

Chicago, Illinois 60605

(312) 795-9121


ATTACHMENT 2


1. Dickerson v. Roger’s Premier Enterprises, LLC, Case No. 13-7154 (January 05, 2015, ND

IL, Judge Finnegan) (D.E. No. 58).

2. Hernandez v. ASG Staffing, Inc., Case No. 12-2068 (December 11, 2014, ND IL, Judge

Bucklo) (D.E. No. 87);

3. Dean, et al. v. Eclipse Advantage Inc., et al., Case No. 11-8285 (December 17, 2013, ND IL,

Magistrate Judge Mason) (D.E. No. 149);

4. Rangel, et al. v. Commonwealth Hospitality, LLC et al., Case No. 12-3809 (December 13,

2013, ND IL, Judge Bucklo) (D. E. 66);

5. Blancas, et al. v. Cairo and Sons Roofing, Co. Inc., Case No. 12-2636 (December 12, 2013,

ND IL, Judge Durkin) (D.E. No. 43);

6. Gallegos et al. v. Midway Building Serivces, LTD et al., Case No. 12-4032 (October 02,

2013, ND IL, Judge Finnegan) (D.E. No. 67);

7. Craig v. EmployBridge et al., Case No. 11 C 3818 (April 4, 2013, ND IL, Judge

Pallmeyer)(D.E. No. 75);

8. Smith et al. v. Dollar Tree Distribution, Inc., Case No. 12-3240 (February 27, 2013, ND IL,

Magistrate Judge Brown) (D.E. No. 35);

9. Ramirez et al. v. Paramount Staffing, Inc. et al., Case No. 11-4163 (January 29, 2013, ND IL,

Magistrate Judge Finnegan)(D.E. No. 40)

10. Bautista et al. v. Real Time Staffing Services, Inc. et al., Case No. 10-0644 (August 28, 2012,

ND IL, Judge Gettleman)(D.E. No. 58);

11. Ochoa et al. v. Fresh Farms International Market, Inc. et al., Case No. 11-2229 (July 10,

2012, ND IL, Judge Dow)(D.E. No. 29);

12. Francisco, et al. v. REM Staffing, et al., Case No. 11-2162 (May 24, 2012, ND IL, Judge

Grady)(D.E. No. 43);

13. Jones et al. v. Simos Insourcing Solutions, Inc. et al., Case No. 11-3331 (May 4, 2012, ND

IL, Judge Bucklo)(D.E. No. 35);

14. Francisco et al. v. Remedial Environmental Manpower, Inc. et al., Case No. 11-2162 (April

25, 2012, ND IL, Judge Grady) (D.E. No. 43)

15. Alvarez et al. v. Staffing Partners, Inc. et al., Case No. 10-6083 (January 17, 2012, ND IL,

Magistrate Judge Finnegan)(D.E. No. 63);

16. Andrade et al. v. Ideal Staffing Solutions, Inc. et al., Case No. 08-4912 (March 29, 2010, ND

IL, Magistrate Judge Denlow) (D.E. No. 142);

17. Arrez et al. v. Kelly Services, Inc., Case No. 07-1289 (October 08, 2009, ND IL, Judge

Leinenweber) (D.E. No. 177);

18. Ortegon, et al. v. Staffing Network, Inc., Case No. 06 CH 12679 (July 24, 2009, Circuit Court

of Cook County);

19. Acosta, et al. vs. Scott Labor, et al., Case No. 05-2518 (March 10, 2008, ND IL, Judge

Gettleman)(D.E. No. 120);

20. Herrera, et al. v. Chicago Mattress, Inc., Case No. 06-1872 (April 27, 2007, ND IL, Judge

Filip)(D.E. No. 49);


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