Notice of Motion and Motion for Order Granting Preliminary Approval 

Case Nos. 3:17-cv-00123-JST/3:17-CV-03850-JST 

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HADSELL STORMER & RENICK, LLP 

Randy Renick (CA SBN 179652) 

 (rrr@hadsellstormer.com) 

Cornelia Dai (CA SBN 207435) 

 (cdai@hadsellstormer.com) 

128 North Fair Oaks Avenue, Suite 204 

Pasadena, California 91103-3645 

Telephone: (626) 585-9600 / Fax: (626) 577-7079 

Lead Plaintiffs’ Counsel 

Attorneys for Plaintiffs Jon Valliere, Eileen Foster, 

Antonio Garcia, Samantha West and the Putative Class 

[Additional Counsel Listed on Next Page] 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

 

JON VALLIERE, EILEEN FOSTER, ANTONIO 

GARCIA, and SAMANTHA WEST, individually 

and on behalf of all similarly situated current and 

former employees, 

 Plaintiffs, 

v. 

TESORO REFINING AND MARKETING 

COMPANY LLC, TESORO LOGISTICS GP, 

LLC, and DOES 1 through 10, inclusive, 

 

 Defendants. 

JINETRA BONNER, individually, on behalf 

herself and all others similarly situated, 

Plaintiffs, 

v. 

TESORO REFINING & MARKETING 

COMPANY, LLC, a Delaware Limited Liability 

Company; and DOES 1 through 100 inclusive, 

Defendants. 

Case No. 3:17-CV-00123-JST 

Case No. 3:17-CV-03850-JST 

CLASS ACTION 

NOTICE OF MOTION AND MOTION FOR 

ORDER GRANTING PRELIMINARY 

APPROVAL OF CLASS ACTION 

SETTLEMENT, CONDITIONAL 

CERTIFICATION, APPROVAL OF CLASS 

NOTICE, AND SETTING OF FINAL 

APPROVAL HEARING 

Date: June 13, 2019 

Time: 2:00 p.m. 

Crtroom: 9 (19th Floor) 

Judge: Hon. Jon S. Tigar 

Case 3:17-cv-00123-JST Document 90 Filed 05/08/19 Page 1 of 4
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Notice of Motion and Motion for Order Granting Preliminary Approval 

Case Nos. 3:17-cv-00123-JST/3:17-CV-03850-JST 

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GILBERT & SACKMAN, A Law Corporation 

Jay Smith (CA SBN 166105) 

 (js@gslaw.org 

Joshua F. Young (CA SBN 232995) 

 (jyoung@gslaw.org) 

Nancy Sotomayor (CA SBN 312022) 

 (nsotomayor@gslaw.org 

3699 Wilshire Boulevard, Suite 1200 

Los Angeles, California 90010 

Telephone: (323) 938-3000 / Fax: (323) 937-9139 

Attorneys for Plaintiffs Jon Valliere, Eileen Foster, 

Antonio Garcia, Samantha West and the Putative Class 

COHELAN KHOURY & SINGER 

Timothy D. Cohelan (CA SBN 60827) 

 (tcohelan@ckslaw.com) 

Michael Singer (CA SBN 115301) 

 (msinger@ckslaw.com) 

Diana M. Khoury (CA SBN 128643) 

 (dkhoury@ckslaw.com) 

J. Jason Hill (CA SBN 179630) 

 (jhill@ckslaw.com) 

605 “C” Street, Suite 200 

San Diego, California 92101 

Telephone: (619) 595-3001 / Fax: (619) 595-3000 

Attorneys for Plaintiff Jinetra Bonner and the Putative Class 

Case 3:17-cv-00123-JST Document 90 Filed 05/08/19 Page 2 of 4
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Notice of Motion and Motion for Order Granting Preliminary Approval 

Case Nos. 3:17-cv-00123-JST/3:17-CV-03850-JST 

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PLEASE TAKE NOTICE that on June 13, 2019 at 2:00 p.m. or as soon thereafter as the matter 

may be heard, in Courtroom 9, 19th Floor of the above-entitled court located at 450 Golden Gate 

Avenue, San Francisco, California 94102, Plaintiffs Jon Valliere, Eileen Foster, Antonio Garcia, 

Samantha West, and Jinetra Bonner, individually and on behalf of all similarly situated current and 

former employees (collectively “Plaintiffs”), and Defendants Tesoro Refining & Marketing Company, 

LLC, and Tesoro Logistics GP, LLC, (“Defendants”) will and hereby do move this Court to: 

 1. Preliminarily approve the non-reversionary $15,250,000 class action settlement 

described in the Joint Stipulation of Class Action Settlement and Release (“Agreement”), attached as 

Exhibit “1” to the Declaration of Randy Renick submitted in support herewith; 

 2. Conditionally certifying the Class (as defined in the Agreement ¶ 3) as a Federal Rules 

of Civil Procedure 23 settlement class; 

 3. Approve and appoint Plaintiffs Jon Valliere, Eileen Foster, Antonio Garcia, Samantha 

West, and Jinetra Bonner as representatives for the proposed Class for purposes of settlement; 

 4. Approve and appoint Hadsell Stormer & Renick, LLP, Gilbert & Sackman, A Law 

Corporation, and Cohelan, Khoury & Singer as Class Counsel for purposes of settlement; 

 5. Approve and appoint CAC Services Group, LLC as the Settlement Administrator; 

 6. Preliminarily approve the application for payment to Class Counsel of reasonable 

attorneys’ fees of up to $3,812,500 (25% of the common fund created) and reasonable costs of up to 

$100,000; 

 6. Preliminarily approve a Service Payment award in the amount of $7,500 to each of the 

five named Plaintiffs for their service, efforts, risks and burdens of acting on behalf of the Class; 

 7. Approving as to form and content the proposed Notice of Class Action Settlement and 

directing its distribution to all members of the Class; and 

 8. Setting a date, time, and place to conduct the Final Approval Hearing on the question of 

whether the proposed Settlement should be finally approved as fair, reasonable, and adequate. 

 This motion is brought pursuant to Federal Rule of Civil Procedure 23 on the grounds that the 

proposed Settlement is fair, reasonable, and adequate, and that all requirements for class certification 

have been met. 

Case 3:17-cv-00123-JST Document 90 Filed 05/08/19 Page 3 of 4
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Notice of Motion and Motion for Order Granting Preliminary Approval 

Case Nos. 3:17-cv-00123-JST/3:17-CV-03850-JST 

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 The motion is based upon this Notice, the Memorandum of Points and Authorities submitted 

herewith, the Declarations of Randy Renick, Joshua Young, and Michael D. Singer, the proposed Joint 

Stipulation of Class Action Settlement and Release, its exhibits and the other records, pleadings, and 

papers filed in this action, and upon such other documentary and oral evidence or argument as may be 

presented to the Court at the hearing on this motion. 

 Respectfully submitted, 

 HADSELL STORMER & RENICK, LLP 

GILBERT & SACKMAN, A Law Corporation 

 COHELAN KHOURY & SINGER 

 

Date: May 8, 2019 By: Randy Renick ____ 

 Randy Renick 

 Attorneys for Plaintiffs and the Proposed Class 

 

 

 

Case 3:17-cv-00123-JST Document 90 Filed 05/08/19 Page 4 of 4