Silvestri vs. Upward Projects Holdings, LLC

3 Silvestri vs. Upward Projects Holdings, LLC

2024-01380452

Plaintiff’s Motion for Approval of Class Settlement

CONTINUED TO 10/23/26 AT 9:00AM IN DEPT CX101 4 Gory vs. Dynamic HR Services LLC

2024-01444604

Plaintiff’s Motion for Approval of Class Settlement Plaintiff’s motion for preliminary approval of class action settlement is CONTINUED to October 30, 2026 at 9:00 a.m. in Department CX101 to permit the parties to respond to the following items of concern. Any supplemental briefing shall be filed on or before October 20, 2026. If a revised settlement agreement and/or class notice is submitted, a redline showing all changes, deletions and additions must be submitted as well. As to the Settlement: 1. Please provide copies of Plaintiff’s pre-filing letter to the LWDA and any amendments thereto.

2. What is the relationship between Dynamic and Streamline? For example, are they two companies under the same overall corporate organization?

3. The GSA is to be paid partially by Dynamic and partially by Streamline. What is the remedy if one of them defaults? Is the other company responsible for the entire GSA? Would the administrator make a partial distribution based on the contribution of the company that paid its share? Etc.

4. Counsel states that Defendants turned over time and pay data for the class. Did Defendants turn over all time and pay data for all class members, or a sample? If a sample, how large (e.g., 10%), and what steps did the parties take to ensure it was representative?

5. Did counsel retain an expert to assist in valuing the case? If so, please provide a CV.

6. Did counsel interview anyone other than Plaintiff to value the non-record claims?

7. Please provide a bid from the settlement administrator.

8. At final approval, please submit contemporaneously made billing records for attorney’s fees and costs. The Court will not be inclined to award an amount of fees and costs greater than the amount stated in the notice.

9. At final approval, please submit billing records for administrative costs. The Court will not be inclined to award administrative costs in an amount greater than the amount stated in the notice.

10. At final approval, Plaintiff is to provide a declaration addressing the enhancement factors set forth in Golba v. Dick’s Sporting Goods, Inc. (2015) 238 Cal.App.4th 1251 and Clark v. Am. Residential Servs. LLC (2009) 175 Cal.App.4th 785, including the amount of time and effort spent on the litigation.

11. At final approval, the administrator is to provide a high, low, and average for individual settlement payments, along with Plaintiff’s individual payout.