1 2 3 Duane A. Admire, State Bar No. 173699 ADMIRE & ASSOCIATES 12880 Carmel Country Road, Suite D110 San Diego, CA 92130 Telephone: (619) 316-6658 Facsimile: (858) 350-1046 4 8 James R. Patterson, State Bar No. 211102 Allison H. Goddard, State Bar No. 211098 Jacquelyn E. Quinn, State Bar No. 314616 PATTERSON LAW GROUP APC 1350 Columbia Street, Suite 603 San Diego, CA 92101 Telephone: (619) 756-6990 Facsimile: (619) 756-6991 9 Attorneys for Plaintiff CARLA JONES 5 6 7 10 11 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF SAN DIEGO – CENTRAL DIVISION 13 14 15 CARLA JONES, on behalf of themselves and all others similarly situated, 16 Plaintiffs, 17 vs. 18 19 20 21 22 [E-FILE] CLASS ACTION SHARP HEALTHCARE, a California Corporation, SHARP GROSSMONT HOSPITAL, and DOES 1- 100, inclusive, Defendants. Case No. 37-2017-00001377-CU-NP-CTL EXHIBITS 16-27 TO DECLARATION OF ALLISON H. GODDARD IN SUPPORT OF MOTION FOR CLASS CERTIFICATION Date: March 9, 2018 Time: 8:30 a.m. Dept.: 74 Judge: Hon. Ronald L. Styn Action Filed: January 12, 2017 Trail Date: None Set 23 (PART 2 OF 2) 24 25 26 27 REDACTED - PUBLIC VERSION 28 30 31 DECLARATION OF ALLISON H. GODDARD IN SUPPORT OF MOTION FOR CLASS CERTIFICATION Case No.: 37-2017-00001377-CU-NP-CTL Exhibit 16 LODGED CONDITIONALLY UNDER SEAL Exhibit 17 LODGED CONDITIONALLY UNDER SEAL Exhibit 18 LODGED CONDITIONALLY UNDER SEAL Exhibit 19 LODGED CONDITIONALLY UNDER SEAL Exhibit 20 LODGED CONDITIONALLY UNDER SEAL Exhibit 21 LODGED CONDITIONALLY UNDER SEAL Exhibit 22 LODGED CONDITIONALLY UNDER SEAL Exhibit 23 LODGED CONDITIONALLY UNDER SEAL Exhibit 24 LODGED CONDITIONALLY UNDER SEAL Exhibit 25 LODGED CONDITIONALLY UNDER SEAL Exhibit 26 Transcript of the Testimony of: Raul Ramos Jones v. Sharp Healthcare September 20, 2017 Volume I CONFIDENTIAL CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · · · · SUPERIOR COURT OF THE STATE OF CALIFORNIA ·2· · · · · · COUNTY OF SAN DIEGO - CENTRAL DIVISION ·3· · · ·4· · · ·5· · · ·6· · · ·7· · · ·8· · · ·9· · · 10· · · 11· · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · ___________________________________ CARLA JONES, on behalf of· · · · · ) themselves and all others· · · · · ) similarly situated,· · · · · · · · ) · · · · · · · · · · · · · · · · · ·) · · · · · · · ·Plaintiffs,· · · · ·) · · · · · · · · · · · · · · · · · ·) · · · · · · · ·-vs-· · · · · · · · ) · · · · · · · · · · · · · · · · · ·) SHARP HEALTHCARE, a California· · ·) Corporation; GROSSMONT HOSPITAL· · ) CORPORATION dba SHARP GROSSMONT· · ) HOSPITAL, a California Corporation ) and DOES 1-100, inclusive,· · · · ·) · · · · · · · · · · · · · · · · · ·) · · · · · · · ·Defendants.· · · · ·) ___________________________________) Case No. 37-201700001377CU-NP-CTL 12 13 14· · · · · · ·CONFIDENTIAL DEPOSITION OF RAUL RAMOS 15· · · · · · · · ·WEDNESDAY, SEPTEMBER 20, 2017 16· · · · · · · · · · · · · 10:08 A.M. 17· · · · · · · · ·501 WEST BROADWAY, SUITE 1000 18· · · · · · · · · · ·SAN DIEGO, CALIFORNIA 19 20 21 22· ·REPORTED BY: 23· ·DEBERA ANNE DORAN 24· ·CSR NO. 7821 25 Page 1 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · that entire device is. ·2· · BY MS. GODDARD: ·3· · · · · · Q· · Do you recall any discussion about whether ·4· · parts of the equipment in the OR was mobile so that you ·5· · couldn't control what the precise field of vision for the ·6· · camera would be? ·7· · · · · · A· · I don't recall a lot of discussion about ·8· · that. ·9· · · · · · Q· · And if you could just explain to me, what 10· · was the motion triggering, I think, that you talked 11· · about, the motion sensor, what was that? 12· · · · · · A· · A certain amount of motion would turn on the 13· · camera to begin recording. 14· · · · · · Q· · Did you set the amount of motion that was 15· · required to start the recording? 16· · · · · · A· · I don't remember. 17· · · · · · Q· · Do you know what was -- how much motion was 18· · required before recording would begin? 19· · · · · · A· · I don't know off the top of my head. 20· · · · · · Q· · And how long would recording -- how long 21· · would there have to be an absence of motion before the 22· · camera stopped recording? 23· · · · · · A· · I don't remember. 24· · · · · · Q· · And as the -- the webcam would turn on and 25· · start recording, correct? Page 54 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · PC. ·2· · · · · · Q· · Okay.· So who's logged on to the PC. ·3· · · · · · · · ·Did you have local administrator access to ·4· · those PCs? ·5· · · · · · A· · Yes. ·6· · · · · · Q· · Do you know anyone else who did? ·7· · · · · · A· · Joseph Scarafone. ·8· · · · · · Q· · Anyone else? ·9· · · · · · A· · To my knowledge, those are the -- he's the 10· · only other person that worked with me on that.· But, 11· · again, anybody with the local administrator account can 12· · access that information. 13· · · · · · Q· · With respect to the videos, how would they 14· · be stored?· Would they be stored -- once a video started 15· · and once it stopped, would that be an individual file? 16· · · · · · A· · To my knowledge, that's how it worked, yeah. 17· · So once it stopped -- it started and then it stopped, 18· · that file would be saved to that directory. 19· · · · · · Q· · Okay.· And was there any -- were those files 20· · backed up or replicated in any other location? 21· · · · · · A· · I know there is an encrypted secure exterior 22· · hard drive where they were often transferred to that was 23· · managed by the information -- sorry -- the physical 24· · security team which is Ray Albright's team at the time. 25· · · · · · Q· · Do you know if they were -- any copies were Page 58 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · · · · · A· · Sorry, say that again. ·2· · · · · · Q· · Did you have any interest in viewing the ·3· · videos so that you could confirm whether or not you were ·4· · able to minimize capturing patient's images on the ·5· · videos? ·6· · · · · · A· · I wasn't -- I wasn't thinking about that. I ·7· · wasn't involved in that operation, like to that extent ·8· · where I was thinking about what's on the videos or not on ·9· · the videos.· I was just more focused on the technical 10· · aspect, like is this project complete?· Do I have a task 11· · associated with it?· Otherwise I was focusing on other 12· · operational matters. 13· · · · · · Q· · There was a refresh that occurred around 14· · March of 2013.· Does that sound familiar? 15· · · · · · A· · I believe there was a refresh incident that 16· · occurred. 17· · · · · · Q· · What is a refresh incident? 18· · · · · · A· · We have a four-year refresh cycle for PCs as 19· · well as monitors and what that means is that we take the 20· · devices that have aged to a certain point and we replace 21· · them with newer devices. 22· · · · · · Q· · And did that affect the monitors and 23· · computers in operating rooms? 24· · · · · · A· · I don't remember the details of the 25· · incident, but if -- again, this is just speculating -- if Page 63 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · a device was removed from the operating room, that would ·2· · disrupt the recording capability because the software ·3· · would no longer be available for the webcam. ·4· · · · · · Q· · Did you select the software? ·5· · · · · · A· · Yes. ·6· · · · · · Q· · Do you recall how much it cost? ·7· · · · · · A· · If I had to just make an approximate guess, ·8· · I think it was under $200 a license, if I recall ·9· · correctly. 10· · · · · · Q· · Was there any discussion -- when were you 11· · trying to look at possible solutions that IS could 12· · propose with respect to the missing drugs, was there any 13· · discussion of potential budget or the maximum amount of 14· · cost involved? 15· · · · · · A· · For the equipment that I was setting up? 16· · · · · · Q· · Yes. 17· · · · · · A· · No. 18· · · · · · Q· · Or for any of the solutions that you looked 19· · at? 20· · · · · · A· · No.· There was no -- there was no concern 21· · that was brought to my attention when I proposed the 22· · solution and said how much it would cost. 23· · · · · · Q· · Okay. 24· · · · · · A· · That was the only time that cost was ever 25· · brought up with the -- that I can remember -- with the Page 64 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · · · · · Q· · Sure. ·2· · · · · · · · ·Since you've been working for Sharp, have ·3· · you ever participated in installing a monitor with a web ·4· · camera in any other operating room in a Sharp facility, ·5· · other than the three at the Grossmont Women's Center? ·6· · · · · · A· · No. ·7· · · · · · Q· · Are you aware of any time since you've been ·8· · working for Sharp where a hidden webcam has been ·9· · installed in an operating room other than the three at 10· · the Grossmont Women's Center? 11· · · · · · A· · I'm not aware. 12· · · · · · Q· · At some point in time, did you delete videos 13· · from the three computers at the Women's Center? 14· · · · · · A· · I remember asking for permission to do so. 15· · · · · · Q· · Who did you ask? 16· · · · · · A· · I believe I asked Ray. 17· · · · · · Q· · And what was his response? 18· · · · · · A· · I don't recall.· Unfortunately, I don't 19· · remember. 20· · · · · · · · ·MS. GODDARD:· Okay.· It's probably a good 21· · time to take a break. 22· · · · · · · · ·(Off the record at 11:33 a.m.) 23· · · · · · · · ·(Recess) 24· · · · · · · · ·(On the record at 12:35 p.m.) 25· · · · · · · · ·MS. GODDARD:· Mr. Ramos, I'm going to mark Page 66 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · see? ·2· · · · · · A· · I hope I would have sent an email or ·3· · communicated with somebody over the phone in saying that ·4· · they were installed in these rooms on these dates and ·5· · these asset tags which identify the computer and the ·6· · monitor. ·7· · · · · · Q· · Would you expect that you would have sent an ·8· · email like that because that's what your typical practice ·9· · is? 10· · · · · · A· · I just want to be complete with the 11· · information and make sure everybody knows when to start, 12· · or the completion of the installation is done. 13· · · · · · Q· · Okay.· Going back to Exhibit 23, do you 14· · recognize Exhibit 23? 15· · · · · · A· · It looks like an email I sent to 16· · Ray Albright and copying Joey Scarafone and Kevin Howell. 17· · · · · · Q· · This is now October 22nd, 2012.· So the 18· · recordings -- the videos had been recording for 19· · approximately three, two-and-a-half months.· Correct? 20· · · · · · A· · It depends.· Because if it's the OR where I 21· · installed it in August, that could change the date or 22· · time frame. 23· · · · · · Q· · But you said here, you say:· Based on our 24· · conversation this morning I deleted all of the August 25· · 2012 recordings so that we have enough space for future Page 94 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · recordings. ·2· · · · · · · · ·Do you see that? ·3· · · · · · A· · Yes. ·4· · · · · · Q· · Did you have a conversation with ·5· · Mr. Albright about that? ·6· · · · · · A· · Based on this email, it looks like I did. ·7· · · · · · Q· · Okay.· And what do you recall about that ·8· · conversation? ·9· · · · · · A· · I don't remember anything. 10· · · · · · Q· · Did you delete the recordings from July 11· · 2012? 12· · · · · · A· · I don't know.· All I can tell you is, based 13· · on this email, it says I deleted all August 2012 14· · recordings. 15· · · · · · Q· · Did you have any discussion with 16· · Mr. Albright about maintaining recordings in a different 17· · location so that it would save up space on the OR PC, but 18· · you'd still have a copy of the recordings? 19· · · · · · A· · It was a concern -- we brought a concern to 20· · Mr. Albright about how we were going to store this and 21· · that space was going to be continue to be a problem.· And 22· · so to the best of my memory, coming up here, close to 23· · August -- or October, I started to send those messages 24· · to -- or started that conversation to say what are we 25· · doing with these recordings and what can I do to free up Page 95 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · space? ·2· · · · · · Q· · And so you recall you did delete the August ·3· · 2012 recordings?· Do you recall that? ·4· · · · · · A· · Based on the email, I can only say that's ·5· · what it says here.· I don't remember doing it. ·6· · · · · · Q· · Okay.· And do you recall saving those ·7· · recordings anywhere prior to deleting them from the PC? ·8· · · · · · A· · I don't remember. ·9· · · · · · Q· · Have you looked to see if you have any 10· · copies of the recordings? 11· · · · · · A· · If I personally have any copies of the 12· · recordings? 13· · · · · · Q· · Or if Sharp personally has any copies of the 14· · recordings anywhere else. 15· · · · · · A· · I don't know where they're stored any 16· · longer.· The last place I heard was the secured encrypted 17· · drive in Ray's office. 18· · · · · · Q· · Did you handle saving the recordings to that 19· · drive? 20· · · · · · A· · That's a good question.· I don't remember. 21· · · · · · Q· · I'm going to show you a document that's 22· · previously been marked as Exhibit 8.· Exhibit 8 is a 23· · two-page document numbered Sharp 84 to 85.· It's an email 24· · dated June 28, 2013 from Raul Ramos to Howard LaBore. 25· · · · · · · · ·Do you recognize Exhibit 8? Page 96 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · and so I removed them and I put them in a secure location ·2· · and as soon as -- it looks like based on this document, ·3· · Ray was told about that.· I'm sure a discussion took ·4· · place and then we were asked to return them. ·5· · · · · · Q· · Okay.· Did you do anything to check the ·6· · computers to be sure that they had not been accessed in ·7· · the time that they had been removed from the security ·8· · office? ·9· · · · · · A· · I made sure to put them in a secure location 10· · in the warehouse which is the on-call cage there.· That's 11· · a locked cage, restricted access, and then I also put 12· · some sort of labeling according to this document here. 13· · · · · · Q· · Do you know what PHI means? 14· · · · · · A· · Yes. 15· · · · · · Q· · What is your understanding? 16· · · · · · · · ·MS. CHOW:· Objection to the extent it calls 17· · for a legal conclusion. 18· · · · · · · · ·You can state your own understanding. 19· · · · · · · · ·THE WITNESS:· So it's protected health 20· · information, but -21· · BY MS. GODDARD: 22· · · · · · Q· · Is PHI normally stored in the SSCF on-call 23· · cage? 24· · · · · · · · ·MS. CHOW:· Again, calls for speculation and 25· · a legal conclusion. Page 103 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · BY MS. GODDARD: ·2· · · · · · Q· · Okay.· Did you take any steps to inform ·3· · yourself as part of implementing the solution of video ·4· · monitors in the operating rooms, to ensure that you had ·5· · checked all Sharp policies regarding the generation of ·6· · PHI on a local computer? ·7· · · · · · A· · The extent of me validating that I had ·8· · authorization to move forward was through my manager or ·9· · director, so Kevin Howell. 10· · · · · · Q· · Okay.· So did you undertake any independent 11· · review of Sharp policies or procedures in implementing 12· · the video monitor solution in the operating rooms at 13· · Sharp Grossmont? 14· · · · · · A· · Beyond what I already knew of the policies, 15· · no. 16· · · · · · Q· · You mentioned that the SSOF on-call cage has 17· · limited access. 18· · · · · · A· · M-hm. 19· · · · · · Q· · Do you know how many people have access to 20· · that cage? 21· · · · · · A· · My team, because they use that as a staging 22· · area.· By "my team," I mean the team that I work on. 23· · · · · · Q· · How many people are on that team? 24· · · · · · A· · At that time, anywhere between 17 and 20. 25· · · · · · Q· · Okay.· And are you aware of anyone else who Page 107 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f CONFIDENTIAL Raul Ramos September 20, 2017 ·1· · had access to that cage besides members of your team? ·2· · · · · · A· · Possibly somebody -- I don't know. I ·3· · honestly don't know who else might have access to that ·4· · cage. ·5· · · · · · Q· · Okay. ·6· · · · · · A· · The access to that cage is also restricted ·7· · by hours.· So even my own team can't access that cage ·8· · until it's after hours.· That's why it's called the ·9· · on-call cage.· So they would even be locked out during 10· · the period of time of business hours, basically. 11· · · · · · Q· · Is there an attendant at the cage? 12· · · · · · A· · No. 13· · · · · · Q· · So in 2013 how did you access the cage? 14· · · · · · A· · With your card badge. 15· · · · · · Q· · Okay. 16· · · · · · · · ·(Exhibit 38 marked) 17· · BY MS. GODDARD: 18· · · · · · Q· · I'm going to mark as Exhibit 38 a series of 19· · documents that were produced to us numbered Sharp 3271 20· · through Sharp 3294.· And I'll just let you know, we got 21· · these produced to us.· I'm not really sure I understand. 22· · And you can take your time to look through them.· They 23· · appear to be emails, but they don't have the headers that 24· · an email would normally have. 25· · · · · · A· · Oh, okay. Page 108 LITIVATE REPORTING + TRIAL SERVICES 877.771.3312 litivate.com YVer1f Exhibit 27 Patterson Law Group is a San Diego, California based commercial litigation firm that focuses on complex class action litigation, including consumer protection, privacy, and employee rights actions. Our firm has been recognized as a leader on both the state and national levels, and attorneys at our firm have been appointed lead counsel, or co-lead counsel in more than 40 state and federal actions. CONSUMER PROTECTION CLASS ACTIONS Our consumer advocacy practice is focused on protecting the privacy rights of consumers. We have litigated numerous cases challenging retailer practices of collecting unnecessary personal information from credit card customers. We have handled a variety of cases involving data breach, internet scams, deceptive marketing, and deceptive banking practices. Representative cases which have been certified as class actions and prosecuted to judgment include: (1) Hernandez v. Restoration Hardware, Inc., Case No. 37-2008-00094395 (San Diego Sup. Ct.) (class receiving benefits of more than $36 million in penalties following trial); (2) Shabaz, Korn v. Polo Ralph Lauren Corp., Case No. SA CV 07-1349 (US Dist. Ct.) (class receiving benefits of more than $10 million); (3) Anderson v. United Retail Group, Case No. 37-2008-00089685 (San Diego Sup. Ct.) (class receiving benefits of approximately $4.2 million); (4) McCarthy v. Euromarket, Case No. 37-2008-00085041 (San Diego Sup. Ct.) (class receiving benefits of approximately $6 million); (5) Johnson v. New York & Company, Case No. 37-2008-00080567, (San Diego Sup. Ct.) (class receiving benefits of approximately $5 million); (6) In Re Citibank Heloc Reduction Litigation, Case No. 09cv0350 (US Dist. Ct.) (class receiving financial benefits as well as reinstatement of equity lines); (7) Lamps Plus Credit Transaction Cases, Case No. JCCP4532 (Los Angeles Sup. Ct.) (class receiving benefits of approximately $6 million); (8) In Re Easysaver Rewards Litigation, Case No. 09cv2094 (US Dist. Ct.) (class receiving benefits of more than $30 million). 1350 Columbia Street, Suite 603  San Diego, CA 92101  619.756.6990  Fax 619.756.6991  www.pattersonlawgroup.com EMPLOYEE RIGHTS ACTIONS Our employee protection practice includes prosecution and trial of both individual and class cases. We have represented employees in many fields, and litigated claims for (1) meal break violations, (2) rest period violations, (3) overtime pay, (4) misclassification, (5) discrimination, (6) wrongful termination, (8) whistle blower, (9) rate violations, (10) unlawful deductions, (11) paystub violations, and (12) private attorney general act claims. Representative cases include: (1) LaMasa, et al. v. INDYMAC Resources, Inc., Case No. 626836 (Stanislaus County Sup. Ct.) (more than $3,000,000 recovered after bank failure and seizure by FDIC); (2) DeLapp v. Union Bank, Case No. CGC-10-500638 (San Francisco Sup. Ct.) (over $1,800,000 recovered for lost vacation pay); (3) Fletcher v. The Toro Company, Case No. 37-2008-00095573 (San Diego Sup. Ct.) (approximately $1,000,000 in compensation recovered for the class of only 119 people); (4) Von Retteg v. La Costa Limousine, Case No. 372008-00086676 (San Diego Sup. Ct.) (approximately $300,000 recovered for the class); (5) Zapata v. BAE Systems Advanced Ceramics, Inc., Case No. 37-2008-00081654 (San Diego Sup. Ct.); (6) Park, et al v. The Blue Buffalo Company, LTD et al, Case No. 3:12cv01274 (US Dist. Ct.) (misclassification); (7) Verdugo v. Richman Management Corporation, Case No. 37- 201000096841 (San Diego Sup. Ct.) (security guard class); (8) Hu et al v. International Rectifier Corporation, Case No. 37- 2010-00096892 (San Diego Sup. Ct.) (unpaid stock benefits). TRIAL EXPERIENCE While we take pride in our ability to appropriately evaluate and favorably resolve complex cases, we are ready willing and able to vigorously litigate any case through trial. The attorneys at Patterson Law Group have significant trial experience, including notable results in Hernandez v. Restoration Hardware (36 million verdict, San Diego Sup. Ct.); Ichor Medical Systems v. Walters (14 million jury verdict, S.D. Cal.), and Oris Medical Systems v. Allion Healthcare (4 million settlement reached mid-trial; San Diego Sup. Ct.). OUR ATTORNEYS JAMES R. PATTERSON is the founder of Patterson Law Group. Prior to founding the firm, Jim spent 6 years with the prestigious national law firm of Cooley LLP, and 6 years with Harrison Patterson & O'Connor LLP. He has been recognized as a leader in both consumer and employee class actions by the media, legislators, and courts throughout the country. Jim has been appointed lead or co-lead counsel in more than 35 state and federal class actions, and has obtained hundreds of millions of dollars in benefits for his clients and class members. He is known as an innovator that will fight the tough fights. Jim is co-lead counsel in the seminal Pineda v. Williams-Sonoma case that changed the prevailing law, and the entire retail industry in California by prohibiting retailers from collecting unnecessary personal identification information from credit card customers. As a result of his in-court success, Jim has been asked to speak at numerous consumer and privacy related conferences, and to opine as to legislation concerning consumer privacy rights in California. Jim's training and experience at Cooley, provides him with a unique perspective on the inner-workings and decision making process of large corporations. His experience on the plaintiffs' side has rounded him into a multi-dimensional and dynamic class action attorney. Jim is a graduate of the University of California at Davis, and the University of San Diego Law School, where he finished magna cum laude and was a member of law review and Order of the Coif. He grew up in the Bay Area and currently resides with his wife and two children in San Diego, California. ALLISON H. GODDARD joined Patterson Law Group, APC at its inception. After graduating from law school in 2000, Ali joined the law firm of Cooley LLP in San Diego, California, where she focused her practice on class actions and complex litigation. She left Cooley in 2004 to found the litigation boutique firm Jaczko Goddard. There, Ali concentrated on intellectual property and general business litigation. In 2011, she joined Patterson Law Group to continue working on intellectual property matters and complex class actions. Ali is very active in the legal community and has served as President of the San Diego Chapter of the Federal Bar Association, Vice Chair of the Host Committee for the 2012 Federal Bar Association National Meetings and Convention. She is currently a Lawyer Representative from the Southern District of California to the Ninth Circuit Judicial Conference. JACQUELYN E. QUINN joined Patterson Law Group as a law clerk in June 2015 and became an associate upon admission to the California Bar in May 2017. Jackie earned her Juris Doctor from Boston University School of Law. While attending law school she served as a judicial extern for the Honorable Joan M. Lewis, California Superior Court. Jackie also served as an Appellate Advocacy Director for Boston University, and competed as a member of the National Appellate Advocacy Moot Court team. Prior to law school, Jackie attended University of California, Davis, where she earned her Bachelor of Arts degree in Psychology and Human Development. Jackie graduated from Boston University School of Law in May 2016 and was admitted to the California Bar in May 2017. ADMINISTRATOR TUPU O’NEILL a paraprofessional and office administrator with more than seven years of experience. In addition to managing the day-to-day operations of Patterson Law Group, Tupu manages cases from inception to trial. She has vast trial experience and has been the sole paraprofessional on multiple class action trials. Tupu is in charge of calendaring, preparation of pleadings, discovery, correspondence, document review and redaction, subpoenas, deposition preparation, case management, docketing control, and filing in both state and federal courts.