[email protected] cplatten@wmprlaw - PFFW · [email protected] 2 T. Reid Coploff(To be...

Case 3:18-cv-05823 Document 1 Filed 09/21/18 of 11

1 Thomas A. Woodley (To be admittedpro hac vice)[email protected]

2 T. Reid Coploff (To be admittedpro hac vice)[email protected]

3 Matthew D. Purushotham (To be admitted pro hac vice)[email protected]

4 WOODLEY & McGILLIVARY LLP1101 Vermont Avenue

5 Suite 1000Washington, DC 20005

6 Telephone: (202) 833-8855Facsimile: (202) 452-1090

7Christopher E. Platten (SBN 111971)

8 [email protected], MCBRIDE, PLATTEN & RENNER

9 2125 Canoas Garden Avenue, Suite 120San Jose, California 95125

10 Telephone: (408) 979-2920Facsimile: (408) 979-2934

11Attorneys for Gary Jacobs, Chris Milano, Sean

12 Reardon, and Mark Way (Plaintiffs)

13 IN THE UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF CALIFORNIA

14

15 GARY JACOBS,CHRIS MILANO,

16 SEAN REARDON, Case No.:

MARK WAY,17

Plaintiffs, COMPLAINT FOR DECLARATORY18 JUDGMENT, COMPENSATION, AND

v. OTHER RELIEF UNDER THE FAIR19 LABOR STANDARDS ACT

I CITY OF BELMONT, CALIFORNIA,20 I

and21 DEMAND FOR JURY TRIAL

BELMONT FERE PROTECTION22 DISTRICT,

23 Defendants.

24

25

26

27

28 Complaint for Violations of theFair Labor Standards Act, Case No.


1 I.

2 INTRODUCTION

31. This action is brought pursuant to the provisions of the Fair Labor

4Standards Act ("FLSA") 29 U.S.C. §§ 201, et seq., to recover from Defendants City ofBelmont,

5

6California, and Belmont Fire Protection District (hereinafter "Defendants") unpaid overtime and

other compensation, interest thereon, liquidated damages, costs of suit and reasonable attorneys'7

8 fees.

9 2. This action arises from Defendantsfailure to include all statutorily required forms

10 of compensation in the "regular rate" used to calculate Plaintiffs' overtime compensation.11

11.

12PARTIES

13

3. The Plaintiffs are current or former employees of the Defendants, and they bring this14

15 action on behalf of themselves and other employees similarly situated. Each of the plaintiffs

16 named herein has given his or her written consent to be a party plaintiff in this action pursuant to

17 29 U.S.C. § 216(b), which is appended hereto as Exhibit A. These written consent forms set forth

18 each plaintiff s name and intent to be a party to this suit. Should other individuals similarly19

situated seek to join this action, their consents will be filed with the Court.20

214. Defendants are political subdivisions of the State ofCalifornia, "public agencies"

22within 29 U.S.C. § 203(x), and are "employers" within 29 U.S.C. § 203(d), and have their

23 principal offices and places of business at One Twin Pines Lane, Suite 230, Belmont, California

24 94002.

25 5. Each of the Defendants was a joint employer of the Plaintiffs for the time period in26

which each defendant was either an employer or acted in the interest of an employer. Each27

Complaint for Violations of the 228 Fair Labor Standards Act


1 defendant is jointly and severally liable for any damages owing to the Plaintiffs, including back

2pay, liquidated damages and attorneysfees.

36. Plaintiffs bring this action on behalf of themselves and all other similarly situated

4individuals. Those individuals constitute a well-defined community of interest in the questions of

5

6law and fact at issue in this case. The claims of the represented Plaintiffs are typical of the claims

of those similarly situated.7

8 111.

9 JURISDICTION AND VENUE

10 7. This action is brought pursuant to the provisions of the FLSA, 29 U.S.C. §§ 201, et11

seq., to recover from Defendants unpaid overtime compensation, interest thereon, liquidated12

damages, costs of suit and reasonable attorneys' fees. This Court has jurisdiction over this action13

14 pursuant to 28 U.S.C. § 1331, 28 U.S.C. §1337, and 29 U.S.C. § 216(b). Venue lies within this

15 District pursuant to 28 U.S.C. §§1391(b)(1) and (b)(2).

16 8. Intradistrict Assignment. This action may be assigned to the San Francisco

17 Division or the Oakland Division pursuant to Local Rule 3-2(d).18 IV.

19FACTUAL ASSERTIONS

209.

21Plaintiffs are, or were, employed by the Defendants within the last three (3) years.

2210. This is an action for a declaratory judgment under 28 U.S.C. §§ 2201 and 2202, and

23 for compensation and other relief under the Fair Labor Standards Act ("FLSA"), 29 U.S.C. § 201,

24 et seq.

25

26

27Complaint for Violations of the 3

28 Fair Labor Standards Act


1 11. At all times relevant hereto, Defendants suffered or permitted Plaintiffs and other

2 similarly situated individuals to work hours beyond statutory thresholds for overtime3

compensation required by the FLSA.4

12. At all tirnes relevant hereto, Defendants impermissibly excluded certain5

6remunerations or undervalued the "regular rate" ofpay, upon which all forms of Plaintiffs'

overtime compensation are based, including but not limited to, monetary compensation in lieu of7

8 Defendants-provided health benefits coverage and compensation in lieu of accrued leave for the

9 Defendantstwelve (12) designated holidays.10 13. Defendants implemented an illegal compensation computation method, which11

undercounts Plaintiffs' "regular rate' of pay. Defendants' method of calculating Plaintiffs'12

"regular rate of pay results, and has resulted in, under-payment for overtime hours worked.13

Defendants suffered or permitted Plaintiffs to perform overtime work without proper14

5 compensation.

16 14. Pursuant to 29 U.S.C. § 207(e), the "regular rate" must include all remuneration

17 received by an employee unless it is explicitly excluded. The burden is on an employer to

18 demonstrate that a payment is excludable from the regular rate. Idaho Sheet Metal Works, Inc. v.19

Wirtz, 383 U.S. 190, 209 (1966); Klem v. Cnty. OfSanta Clara, Cal., 208 F.3d 1085, 1089 (9th20

Cir. 2000). Defendants' past and current practice of computing Plaintiffs' overtime has21

22 impermissibly reduced the amount being paid to Plaintiffs by failing to compute all statutorily

23 required amounts into Plaintiffs' "regular rate" of pay as defined by 29 U.S.C. § 207(e).

24

25

26




1 A. Cash-in-Lieu Payments

2 15. Defendants failed to include monetary compensation paid to Plaintiffs, who3

declined Defendants-provided health insurance, in the "regular rate" used to calculate Plaintiffs'4

overtime compensation.5

616. As part of the compensation it provided Plaintiffs, Defendants paid Plaintiffs and

other similarly situated individuals monetary compensation in lieu of contributing towards7

8 Defendants-provided health benefits coverage ("Cash-in-Lieu").

9 17. In calculating the "regular rate for the purposes ofovertime compensation,

10 Defendants excluded the remunerations it paid Plaintiffs and similarly-situated individuals in lieu11

of contributions towards health insurance.12

18. At all times relevant hereto, Defendants placed no condition on use of these Cash-13

14in-Lieu payments.

15 19. At all times relevant hereto, Defendants treated these payments to Plaintiffs as

16 wages for the purposes of applicable tax withholdings.

17 20. Pursuant to 29 U.S.C. § 207(e), Defendants are statutorily required to include all

18 forms of remuneration in Plaintiffs' "regular rate/5 of pay.19

21. 29 U.S.C. § 207(e)(2), which allows employers to exclude from the "regular rate"20

21payments for periods where no work is performed, reasonable payments for traveling expenses or

22other expenses incurred by employees, and other similar payments which are not made as

23 compensation for employeeswork, does not allow Defendants to exclude monetary compensation

24 paid to Plaintiffs, and similarly situated individuals, in lieu of contributions for health benefits.

25

26




1 22. The same is true for 29 U.S.C. § 207(e)(4), which allows employers to exclude

2 from the "regular rate" contributions they irrevocably make to a trustee or third person pursuant to3

a "bona fide plan" for providing health insurance benefits.4

23. The Department of Labor's interpretation of the term "bona fide plan" is set forth in5

629 C.F.R. § 778.215(a)(5), which states in part:

7 The plan must not give an employee the right to assign his benefitsunder the plan nor the option to receive any part of the employer's

8 contributions in cash instead of the benefits under the plan:Provided, however, that if a plan otherwise qualified as a bona fide

9 benefit plan under section 7(e)(4) of the Act, it will still be regardedas a bona fide plan even though it provides, as an incidental part10 thereof, for the payment to an employee in cash of all or a part of

11 the amount standing to his credit.

12 24. In Flores v. City ofSan Gabriel, 824 F.3d 890 (9th Cir. 2016), the Ninth Circuit

13 Court ofAppeals held that payments to employees in lieu ofhealth benefits were not excludable

14 from the "regular rate" of pay under either 29 U.S.C. §§ 207(e)(2) or (e)(4). With respect to the15

exclusion codified in § 207(e)(2) and its companion federal regulation, the court noted "Under [2916

17C.F.R.] § 778.224(a), a payment may not be excluded from the "regular rate" ofpay pursuant to §

8 207(e)(2) if it is generally understood as compensation for work, even though the payment is not

119 directly tied to specific hours worked by an employee." (Id.) Further, the appellate court held that

20 cash payments in lieu of health benefits are not excludable from the "regular rate" under §

21, 207(e)(4) because those payments do not have to be tied to specific hours ofwork or non-work.22

25. Because the remunerations paid to Plaintiffs, and similarly situated individuals, in23

lieu of health benefits were not made for hours of non-work or, on information and belief, made24

25pursuant to a bona benefit plan, they must be included in the "regular rate" of pay for determining

261 overtime compensation as required by the FLSA.

27'



1 26. At all times relevant hereto, Defendants through pattern and practice did not

2 include the monetary compensation it provided in lieu of health benefits into the "regular rate" of3

pay for the purposes of determining overtime compensation as required by the FLSA.4

27. Plaintiffs are informed and allege that payments Defendants made in lieu of5

6Plaintiffsand other similarly situated individuals' health insurance were not made pursuant to a

"bona fide plan" for the provision ofmedical benefits within the meaning of 29 U.S.C. § 207(e)(4)7

8 and 29 C.F.R. § 778.215.

9 B. Holiday-in-Lieu Payments

10 28. •Defendants failed to include monetary compensation paid to Plaintiffs in lieu of11

accrued leave for holidays ("Holiday-in-Lieu pay"), in the "regular rate used to calculate12

Plaintiffs' overtime compensation.13

1429. As part of the compensation it provided Plaintiffs, Defendants paid Plaintiffs and

15 other similarly situated individuals monetary compensation in lieu of awarding them accrued leave

16 for the Defendants' twelve (12) designated holidays.

17 30. ln calculating the "regular rate" for the purposes of overtime compensation,18

Defendants excluded the remunerations it paid Plaintiffs and similarly-situated individuals in lieu19

of awarding them accrued leave for the Defendants' twelve (12) designated holidays.20

2131. The Defendants made Holiday-in-Lieu payments to Plaintiffs and similarly-situated

22individuals at the rate of six hours per pay period, regardless ofwhether holidays fall within the

23 pay periods.

24 32. 29 U.S.C. § 207(e)(2) allows employers to exclude from the regular rate "payments

25 made for occasional periods when no work is performed due to vacation, holiday, illness... or26

similar cause. (emphasis added).27



1 33. This Court has ruled that where additional compensation for holidays is paid every2pay period regardless ofwhether employees work the holidays and regardless ofwhether a holiday

3falls within the pay period, such Holiday-in-Lieu pay is not provided "due te a holiday and must

4be included in the employeesregular rates ofpay. See, e.g., Hart v. Cnty ofAlameda, No. C-07-

5

65845 MMC, 2009 BL 129793, *3 (N.D. Cal. June 17, 2009).

C. Exclusion from Regular Rate of Cash-in-Lieu and Holiday-in-Lieu Payments7

8 34. By excluding these Cash-in-Lieu and Holiday-in-Lieu paynlents and other forms of

9 compensation from the "regular rate" used to calculate overtime compensation paid to Plaintiffs

10 and other similarly situated individuals, Defendants failed to pay them one and one-half times their

11"regular rate of pay for all hours of overtime they worked.

1235. At all times relevant hereto, Defendants and their agents and representatives were

13

14aware of their obligations to properly compute and use the correct "regular rate" of pay in

15 calculating overtime compensation owed to Plaintiffs and similarly situated individuals.

16 36. Plaintiffs are informed and allege Defendants and their agents and/or

17 representatives willfully, knowingly, and recklessly violated the FLSA by continuing to exclude18 remunerations from the calculation ofPlaintiffs' and similarly situated individuals' "regular rate"19

of pay.20

2137. Defendants' failures to properly compensate Plaintiffs and similarly situated

22individuals are not in good faith and on reasonable grounds, and are willful and reckless violations

23 of the FLSA.

24 38. As a result of the foregoing violations of the FLSA alleged herein, Plaintiffs seek

25 damages for lost overtime compensation, as well as liquidated damages. Plaintiffs seek these26




1 damages for the entire period of time Defendants have engaged in said unlawful, willful and

2 reckless conduct, up to three years as prescribed by the FLSA.3

39. Plaintiffs also seek reasonable attorneysfees and costs pursuant to 29 U.S.C. §4

216(b).5

FIRST COUNT6

(Fair Labor Standards Act - Failure to Pay All Overtime Compensation Earned)7

8 40. Plaintiffs incorporate by reference each and every paragraph above inclusive as

9 though set forth fully herein.

10 41. Defendants suffered or permitted Plaintiffs, and other similarly situated individuals,11

to work overtime but failed to include all required forms of compensation into the "regular rate" of12

pay used to calculate their overtime compensation.13

1442. By failing to include all requisite forms of compensation in the "regular rate" ofpay

15 used to calculate overtime compensation, Defendants failed to compensate Plaintiffs and similarly

16 situated individuals at one and one-half times the "regular rate" ofpay for all overtime hours as

17 required by the FLSA.

1843. At all times relevant hereto, Defendants and their agents and representatives were

19aware of their obligations to pay Plaintiffs and similarly situated individuals for all hours worked

20

21at one and one-half times the "regular rate" of pay as required by the FLSA.

2244. At all times relevant hereto, Defendants and their agents and representatives knew

23 or should have known of their obligations to pay Plaintiffs and similarly situated individuals

24 overtime compensation at one and one-half of their regular rate of pay for all hours worked in

25 excess of the applicable maximum weekly hours established by § 207 of the FLSA.26




1 45. At all times relevant hereto, Defendantsfailures to fully compensate Plaintiffs for

2 all hours worked have not been in good faith and on reasonable grounds, and are willful and

3reckless violations of the FLSA.

446. As a result of the foregoing violations of the FLSA as herein enumerated, Plaintiffs

5

6seek damages for three (3) years' back pay for unlawfully withheld overtime compensation that

was earned but unpaid, as well as an equal amount in liquidated damages.7

8 47. Plaintiffs also seek reasonable attorneys' fees and costs pursuant to 29 U.S.C. §

9 216(b).

10 PRAYER

1 1WHEREFORE, Plaintiffs pray judgment as follows:

121. For recovery of unpaid overtime compensation and interest thereon plus an equal

13

14amount of liquidated damages for Plaintiffs and all similarly situated individuals pursuant to

15 29 U.S.C. § 216(b).

16 2. For a determination that Defendants' actions and omissions were knowing, willful

17 and reckless violations of the FLSA, and were unreasonable and lacking in good faith, and

18 therefore Plaintiffs are entitled to recover unpaid overtime compensation and liquidated damages19

under a three (3) year statute of limitations;20

3. For reasonable attorneys' fees pursuant to 29 U.S.C. § 216(b);21

224. For costs incurred as a result of this proceeding;

23 5. For injunctive relief ordering the Defendants to cease and desist from engaging in

24 said unlawful conduct, including but not limited to, revisions to applicable compensation policies

25 to clearly indicate that cash paid in lieu of health benefits and Holiday-in-lieu ofpayments will be26

included in the "regular rate" of pay for the purposes of overtime compensation.27



1 6. For such other and further relief as the court deems just and proper.

2

3JURY TRIAL DEMAND

4Pursuant to Rule 38 of the Federal Rules ofCivil Procedure, Plaintiffs hereby respectfully

5

6request a trial by jury on all claims presented in this Complaint.

7 Dated: September 21, 2018 Respectfully submitted,

8/s/Thomas A. Woodley

9 Thomas A. WoodleyT. Reid Coploff

10 Matthew D. PurushothamWOODLEY & McGILLIVARY LLP

11 1101 Vermont Ave., N.W.

12 Suite 1000Washington, DC 20005

13 Phone: (202) [email protected]

14 [email protected]

[email protected]

16/s/Christopher E. Platten

17 Christopher E. PlattenWYLIE, MCBRIDE, PLATTEN & RENNER

18 2125 Canoas Garden Avenue, Suite 120San Jose, California 95125

19 Telephone: (408) 979-292020 Facsimile: (408) 979-2934

[email protected]

Attorneysfor Plaintiffs'22

23

24

25

26



Case 3:18-cv-05823 Document 1-1 Filed 09/21/18 Page 1 of 5

EXHIBIT A


Consent to Become PlaintiffIn a Wage and Hour Overtime Lawsuit

I hereby consent to be a party plaintiff in a lawsuit under the Fair Labor Standards Act

concerning my employment with the Belmont Fire Protection District to recover unpaid overtime

compensation and other relief.

PrintName Cle. y

.4 IIsiTr: ture

69r tA -act n S



I hereby consent to be a party plaintiff in a lawsuit under the FairLabor Standards Act

concerning my employment with the Belmont Fire ProtectionDistrict to recover unpaid overtime


01.(g.i SI-Of/1-4E1Z • MI LAAJOPrint Name Clearly

CSignature






Sea, &WonPrint Name Clearly

Signature






Sitft e

trokh utiFyiPrint Name Clearly

Case 3:18-cv-05823 Document 1-2 Filed 09/21/18 Page 1 of 2JS-CAND 44 (Rev. 06/17) CIVIL COVER SHEETThe JS-CAND 44 civil cover sheet and the infonnation contained herein neither replace nor supplement the filing and service ofpleadings or other papers as required by law,except asprovided bylocal rules of court. This form, approved in its original form by the Judicial Conference ofthe United States in September 1974, is required for the Clerk of

iCourt to nitiate the civil docket sheet. (SEE INSTRUCTIONS ONNEXTPAGE OF THIS FORM)

(a) PLAINTIFFS DEFENDANTSUary Jacobs, Chris Milano, Sean Reardon, and Mark Wayl City ofBelmont, California and Belmont Fire Protection District(b) County ofResidence ofFirst Listed Plaintiff Yolo County County ofResidence ofFirst Listed Defendant San Mateo County

(EXCEPTIN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)NOTE: INLAND CONDEMNATION CASES, USE THE LOCATION OF

THE TRACT OF LAND INVOLVED.

(C) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (IfKnown)

See Exhibit A attached

II. BASIS OF JURISDICTION (Place an X" in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One BoxforPlaintiff(ForDiversity Cases Only) and One BoxforDefendant)

PTF DEF PTF DEF1 U.S. Government Plaintiff x 3 Federal Question Citizen ofThis State 1 I Incorporated or Principal Place 4 4(U.S. GovernmentNot a Party)ofBusiness In This State

Citizen ofAnother State 2 2 Incoiporated and Principal Place 5 52 U.S. Government Defendant 4 Diversity

(Indicate Citizenslup ofParties in Item III) of Business In Another StateCitizen or Subject ofa 3 3 ForeignNation 6 6

Foreign County

IV. NATURE OF SUIT (Place an "X" in One Box Only) •

CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Dmg Related Seizure of 422 Appeal 28 USC § 158 375 False Claims Act120 Marine 310 Airplane 365 Personal Injury — Product Property 21 USC § 881 423 Withdrawal 28 USC 376 Qui Tam(31 USC130 Miller Act 315 Airplane Product Liability Liability 690 Other § 157 § 3729(a))140 Negotiable Insttument 320 Assault, Libel & Slander 367 Health Care/ LABOR PROPERTY RIGHTS 400 State Reapportionment150 Recovery of 330 Federal EmployersPharmaceutical Personal X 710 Fair Labor Standards Act 820 Copyrights

410 AntitrustOveipayment Of Liability Injury Product Liability

720 Labor/Management 830 Patent430 Banks and Banking

Veteran's Benefits 368 Asbestos Personal Injury340 Marine Relations 450 Commerce151 Medicare Act Product Liability 835 Patent—Abbreviated New

345 Marine Product Liability 740 Railway Labor Act DrugApplication 460 Deportation152 Recovery ofDefaulted PERSONALFROPERTY350 Motor Vehicle 751 Family and Medical 840 Trademark 470 Racketeer influenced &

Student Loans (Excludes 370 Other Fraud Leave Act Commt OrganizationsVeterans) 355 Motor Vehicle Product I

Liability 371 Tmth in Lending 790 Other Labor LitigationSOCIAL SECURITY

480 ConsumerCredit153 Recovery of 380 Other Personal Property 861 HIA (1395ff) 490 Cable/Sat TVOverpayment 360 Other Personal Injury 791 Employee Retirement

Damage 862 Black Lung (923)ofVeteran's Benefits 362 Personal Injury -Medical. Income Security Act 850 Securities/Commodities/

Malmactice 385 Property Damage Product 863 DIWC/DIWW (405(g)) Exchange160 Stockholders' Suits Liability IMMIGRATION864 SSD) Title XVI 890 Other Statutory Actions190 Other Contract 462 NaturalizationCIVIL RIGHTS PRISONER PETITIONS 865 RSI (405(g)) 891 Agricultural Acts195 Contract Product Liability Application

440 Other Civil Rights HABEAS CORPUS 465 Other immigration FEDERAL TAX SUITS 893 Environmental Matters196 Franchise

441 Voting 463 Alien Detainee Actions 870 Taxes (U.S. Plaintiff or89 Freedom ofInformation

REAL PROPERTY Act442 Employment 510 Motions to Vacate Defendant)210 Land Condemnation 443 Housing/ Sentence 871 IRS—Third Party 26 USC

896 Arbitration

220 Foreclosure Accommodations 530 General § 7609 899 Administrative Procedure

230 Rent Lease & Ejectment 445 Amer. w/Disabilities— 535 Death Penalty Act/Review or Appeal of

240 Torts to Land Employment OTHERAgency Decision

245 Tort Product Liability 446 Amer. w/Disabilifies—Other 540 Mandamus & Other950 Constitutionality of State

Statutes290 All Other Real Property 448 Education 550 Civil Rights

555 Prison Condition

560 Civil Detainee—Conditions ofConfinement

V. ORIGIN (Place an "X" in One Box Only)X 1 Original 2 Removed from 3. Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict

Proceeding State Court '

Appellate Court Reopened Another District (speci)9 Litigation—Transfer Litigation—Direct File

VI. CAUSE OF Cite the U.S. Civil Statute underwhich you are filing (Do not cite jurisdictional statutes unless diversity):

ACTION Fair Labor Standards Act

Brief description ofcause:.Failure to pay all overtime compensation owed due to improper exclusion of certain payments from the calculation of employees' regular rates ofpay.

VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECKYES only ifdemanded in complaint:COMPLAINT: UNDER RULE 23, Fed. R. Civ. P. JURY DEMAND: X Yes No

VIII. RELATED CASE(S), JUDGE DOCKET NUMBERIF ANY (See instructions):

IX. DIVISIONAL ASSIGNMENT (Civil Local Rule 3-2)(Place an "V in One Box Only) x SAN FRANCISCO/OAKLAND SAN JOSE EUREKA-MCKINLEYVILLE

DATE 09/21/2018 SIGNATURE OF ATTORNEY OFRECORD


Exhibit A

Attorneys for Plaintiff:

Thomas A. WoodleyWOODLEY & McGILLIVARY LLP1101 Vermont Avenue, N.W.Suite 1000

Washington, DC 20005Phone: (202) 833-8855Fax: (202) [email protected]

T. Reid CoploffWOODLEY & McGILLIVARY LLP1101 Vermont Avenue, N.W.Suite 1000Washington, DC 20005Phone: (202) 833-8855Fax: (202) [email protected]

Matthew D. PurushotharnWOODLEY & McGILLIVARY LLP1101 Vermont Avenue, N.W.Suite 1000

Washington, DC 20005Phone: (202) 833-8855Fax: (202) [email protected]

Christopher E. Platten (SBN 111971)WYLIE, MCBRIDE, PLATTEN & RENNER2125 Canoas Garden Avenue, Suite 120San Jose, California 95125Telephone: (408) 979-2920Facsimile: (408) [email protected]

[email protected] cplatten@wmprlaw - PFFW · [email protected] 2 T. Reid Coploff(To be...

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