Jeff Jonah v. Kimberly-Clark Corporation et al

Northern District of California, cand-4:2015-cv-03243

Exhibit A

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Exhibit A Plaintiffs Asserting (States purchased) Cause of Action Classes and Subclasses on behalf of Whom Claims Are Asserted Per Proposed Compl. ¶ 165 First Cause of Action - Cal. Civil Code Jennifer Davidson (CA) Class: All persons who, between March 13, 2010 Consumer Deception Statute Subclass: All class California Subclass: All Class Illinois Subclass: All Class § 1750 (CLRA) & Statutes Listed in Jeff Jonah (CA) and the present, purchased, in 49 States and the members who purchased the products in the members who made their members who made their Appendix 1 Angela Lewis (CA) District of Columbia, excepting all purchases in the following states, subject to the state's statute of purchases in California since purchases in California since Edward Colatori (CA, FL, IL) State of New York, any of the following products: limitations: Alabama, Alaska, Arkansas, California, March 13, 2010. January 29, 2016. Cottonelle® Fresh Care Flushable Wipes & Colorado, Delaware, District of Columbia, Cleansing Cloths, Scott Naturals® Flushable Moist Georgia, Idaho, Illinois, Indiana, Kansas, Maryland, Wipes, Huggies® Pull-Ups® Flushable Moist Michigan, Minnesota, Mississippi, Nebraska, Wipes, and U by Kotex® Refresh flushable wipes. Nevada, New Hampshire, New Mexico, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, Tennessee, Texas, Utah, Virginia, West Virginia, Wyoming. Second Cause of Action - Cal. Bus. & Jennifer Davidson (CA) California Subclass: All Class members who made Prof. Code § 17500 Jeff Jonah (CA) their purchases in California since March 13, 2010. Angela Lewis (CA) Edward Colatori (CA, FL, IL) Third Cause of Action - Fraud Jennifer Davidson (CA) California Subclass: All Class members who made Jeff Jonah (CA) their purchases in California since March 13, 2010. Angela Lewis (CA) Edward Colatori (CA, FL, IL) Fourth Cause of Action - Negligent Jennifer Davidson (CA) California Subclass: All Class members who made Misrepresentation Jeff Jonah (CA) their purchases in California since March 13, 2010. Angela Lewis (CA) Edward Colatori (CA, FL, IL) Fifth Cause of Action - Unjust Jennifer Davidson (CA) Class: All persons who, between March 13, 2010 California Subclass: All Class members who made Florida Subclass: All Class Illinois Subclass: All Class North Carolina Subclass: All Washington Subclass: All Enrichment Jeff Jonah (CA) and the present, purchased, in 49 States and the their purchases in California since March 13, 2010. members who made their members who made their Class members who made their Class members who made their Angela Lewis (CA) District of Columbia, excepting all purchases in the purchases in Florida since purchases in California since purchases in California since purchases in California since Edward Colatori (CA, FL, IL) State of New York, any of the following products: January 29, 2015. January 29, 2016. January 29, 2015. January 29, 2015. Amber Walsh (WA) Cottonelle® Fresh Care Flushable Wipes & RiSha Mattingly (NC) Cleansing Cloths, Scott Naturals® Flushable Moist Wipes, Huggies® Pull-Ups® Flushable Moist Wipes, and U by Kotex® Refresh flushable wipes. Sixth Cause of Action - Magnuson- Jennifer Davidson (CA) Class: All persons who, between March 13, 2010 California Subclass: All Class members who made Florida Subclass: All Class Illinois Subclass: All Class North Carolina Subclass: All Washington Subclass: All Moss Warranty Act Jeff Jonah (CA) and the present, purchased, in 49 States and the their purchases in California since March 13, 2010. members who made their members who made their Class members who made their Class members who made their Angela Lewis (CA) District of Columbia, excepting all purchases in the purchases in Florida since purchases in California since purchases in California since purchases in California since Edward Colatori (CA, FL, IL) State of New York, any of the following products: January 29, 2015. January 29, 2016. January 29, 2015. January 29, 2015. Amber Walsh (WA) Cottonelle® Fresh Care Flushable Wipes & RiSha Mattingly (NC) Cleansing Cloths, Scott Naturals® Flushable Moist Wipes, Huggies® Pull-Ups® Flushable Moist Wipes, and U by Kotex® Refresh flushable wipes. Seventh Cause of Action - Express Jennifer Davidson (CA) Warranty Subclass: All class members whose Express Warranty Reliance Subclass: All California Subclass: All Class Florida Subclass: All Class Illinois Subclass: All Class North Carolina Subclass: All Washington Subclass: All Warranty (UCC § 2-313) Claims Listed Jeff Jonah (CA) purchases were made in a state other than members of the Class whose purchases were made members who made their members who made their members who made their Class members who made their Class members who made their in Appendix 2 Angela Lewis (CA) Louisiana. in Alaska, Arizona, Arkansas, California, Colorado, purchases in California since purchases in Florida since purchases in California since purchases in California since purchases in California since Edward Colatori (CA, FL, IL) Connecticut, Delaware, Florida, Iowa, Kentucky, March 13, 2010. January 29, 2015. January 29, 2016. January 29, 2015. January 29, 2015. Amber Walsh (WA) Maine, Maryland, Massachusetts, Michigan, RiSha Mattingly (NC) Mississippi, Montana, Nebraska, New York, North Carolina, Ohio, Oklahoma, Oregon, Rhode Island, South Dakota, Tennessee, Texas, Utah, Washington, or Wyoming. Eighth Cause of Action - Implied Jennifer Davidson (CA) Warranty Subclass: All class members whose Implied Warranty Privity Subclass: All members California Subclass: All Class Florida Subclass: All Class Illinois Subclass: All Class North Carolina Subclass: All Washington Subclass: All Warranty (UCC § 2-314) Claims Listed Jeff Jonah (CA) purchases were made in a state other than of the Express Warranty Reliance Subclass whose members who made their members who made their members who made their Class members who made their Class members who made their in Appendix 3 Angela Lewis (CA) Louisiana. purchases were made in Alabama, Arizona, purchases in California since purchases in Florida since purchases in California since purchases in California since purchases in California since Edward Colatori (CA, FL, IL) California, Connecticut, Florida, Georgia, Idaho, March 13, 2010. January 29, 2015. January 29, 2016. January 29, 2015. January 29, 2015. Amber Walsh (WA) Illinois, Kentucky, New York, North Carolina, RiSha Mattingly (NC) Ohio, Tennesee, Washington, or Wisconsin. Plaintiffs Asserting (States purchased) Cause of Action Classes and Subclasses on behalf of Whom Claims Are Asserted Per Proposed Compl. ¶ 165 Ninth Cause of Action - Cal. Bus. & Jennifer Davidson (CA) Consumer California Subclass: All Class members who made Florida Subclass: All Class Illinois Subclass: All Class North Carolina Subclass: All Washington Subclass: All Prof. Code § 17200 & Statutes Listed Jeff Jonah (CA) Deceptiveness/Unfairness/Unlawfulness their purchases in California since March 13, 2010. members who made their members who made their Class members who made their Class members who made their in Appendix 1 Angela Lewis (CA) Statute Subclass: All class members who purchases in Florida since purchases in California since purchases in California since purchases in California since Edward Colatori (CA, FL, IL) purchased the products in the following states, January 29, 2015. January 29, 2016. January 29, 2015. January 29, 2015. Amber Walsh (WA) subject to the state's statute of limitations: RiSha Mattingly (NC) Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming.