Molina et al v. Ace Homecare LLC

Middle District of Florida, flmd-8:2016-cv-02214

AFFIDAVIT of Chad A. Justice, Esq. re: {{25}} First MOTION to Certify Class by Toni Molina.

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UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION TONI MOLINA, ERICA TOVAR, TARA WARD, LY NGUYEN, CONSUELO POWELL DONALD HALL, and DEBBIE BURGESS, on behalf of themselves and all others similarly situated, Plaintiffs, v. Case Number: 8:16-cv-02214-JDW-TGW ACE HOMECARE, LLC, BRL INVESTMENTS, LLC, ARTHUR BARLAAN, and JOCELYN BARLAAN, Defendants. _______________________________/DECLARATION OF CHAD A. JUSTICE I, Chad A. Justice, declare under penalty of perjury as follows: 1. My name is Chad A. Justice. Unless otherwise indicated, the facts set forth below are based on my personal knowledge and the opinions set forth herein are my own. I understand that this declaration under oath may be filed in the above captioned action. 2. I am a partner at Black Rock Trial Lawyers LLC and co-counsel in the above-styled case. Black Rock Trial Lawyers LLC is a Tampa based law firm, located at 201 S. Westland Avenue, Tampa, FL 33606. We were recently founded in 2016. 3. I am the exclusive practitioner of employment law with Black Rock Trial Group which is a firm consisting of four (4) other attorneys in their respective practice areas, including Vivian Canals, immigration; Lara Lavoie, personal injury; Juan Sanchez, business litigation; and Jessica Lowe, real estate. 4. I am a licensed attorney in Florida. I have been a member of the Florida Bar since April 13, 2016, and have practiced exclusively labor and employment law since that time. 5. In 2017, I was recognized by the Tampa Magazine as a "Top Lawyer" in Labor and Employment. I have a J.D. from Western Michigan University, Thomas M. Cooley Law School, and a Bachelor’s degrees from the University of Michigan, Flint. 6. I am admitted in the United States District Courts for the Middle and Southern District of Florida. 7. I have represented employees in many stages of litigation in federal and state courts throughout Florida. In the Middle District of Florida and the Southern District of Florida combined, I have served as co-counsel or lead counsel in 13 federal cases. 8. Currently, I am lead, or co-counsel in multiple putative class action cases, including cases brought under the Fair Labor Standards Act, Fair Credit Reporting Act and ERISA. These cases include: Vazquez v. Marriott International, Inc., 8:17-cv-00116 (M.D. Fla), Valdivieso v. Cushman & Wakefield Inc., 8:17-cv-00118 (M.D. Fla), Stephens v. Walmart Stores, Inc., 0:16-cv-62723 (S.D. Fla), Bryant v. Wal-Mart Stores, Inc., 1:16-cv-24818 (S.D. Fla). 9. In each of these cases I gained experience investigating, selecting, and litigating class actions. 10. Named Plaintiff, Toni Molina, originally contact me to represent her and a group of former employees of Defendant to recoup unpaid wages and to bring a putative WARN Act claims against the Defendants. I filed the original Complaint in this action. (Docket 1). After being contacted by several other potential Plaintiffs and discussing the matter with each Plaintiff, I decided to recruit my former law firm, Wenzel Fenton Cabassa, P.A. who I had worked for for three (3) years to ensure Plaintiff had the attorneys with the requisite class action experience. 11. I have been involved in every stage of this litigation, including bearing the costs, attending depositions, attending mediations, assisting with brief writing, attending oral argument on class certification, and every other thing necessary to prosecute the class claims in this case. 12. At this point, I believe I possess the necessary experience to represent the WARN Act class that Plaintiffs seek to have certified. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct. Dated this 15th day September, 2017./s/Chad A, Justice CHAD A. JUSTICE