EXHIBIT B
WOODROW & PELUSO, LLC FIRM RESUME

WOODROW & PELUSO, LLC (“Woodrow & Peluso” or the “firm”) is a plaintiff’s class

action and commercial litigation firm based in Denver, Colorado. The firm files cases across the

Country.

Our attorneys have over a decade of experience successfully representing consumers and

small businesses in matters nationwide. From litigation under the Telephone Consumer Protection

Act, 47 U.S.C. § 227 et seq., to cases enforcing the rights of job applicants and employees under

the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq., to appeals of first impression, our lawyers

have litigated and favorably resolved numerous legal disputes to the satisfaction of our clients. At

Woodrow & Peluso, LLC, we take special pride in the quality of our work product and strive

tirelessly to achieve the best results for every client. Descriptions of our three primary practice

areas—(1) Consumer Class Actions, (2) Commercial Litigation, and (3) Appeals—and key

personnel follow.

OUR PRACTICE AREAS

1. CONSUMER CLASS ACTIONS

The majority of the firm’s caseload focuses on consumer class actions. These cases include

class actions alleging violations of statutes, such as the Fair Credit Reporting Act, the Telephone

Consumer Protection Act, and the Truth-in-Lending Act, as well as class actions challenging

systematic breaches of contract and advancing other common law theories.

TCPA Class Actions

Woodrow & Peluso attorneys have successfully litigated and settled numerous class actions

challenging violations of the Telephone Consumer Protection Act. To date we have filed,

prosecuted, and resolved using various settlement models TCPA cases against major corporations

and entities including Rita's Italian Ice, Global Marketing Research Services, LKQ Corporation,

J.B. Hunt, Altisource, Acurian, Price Self Storage, Local Lighthouse, Geekatoo, and the University

of South Carolina, among others. Our firm’s attorneys have substantial experience prosecuting

such claims, including class actions challenging the unlawful transmission of text messages, the

sending of unlawful facsimiles, the placement of “robocalls” featuring a pre-recorded voice to

residential landline phones, and the use of automatic telephone dialing systems, including

predictive dialers, to call consumer cell phones.

Notable TCPA cases and settlements include:

• Wendell H. Stone & Co. v. LKQ Corporation, 16-cv-07648 (N.D. Ill) (Kennelly, J.)

(granting final approval to all-in, non-reversionary, settlement fund of $3,266,500) (final

approval granted May 16, 2017).

• Martin et al. v. Global Marketing Research Services, Inc., 6:14-cv-1290-ORL-31-KRS

(M.D. FL) (Woodrow & Peluso appointed co-lead Settlement Class Counsel in

settlement creating $10 million fund for class of 688,500 cellphone users) (final approval
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granted November 4, 2016);

• Mendez v. Price Self Storage Management, Inc., 3:15-cv-02077-AJB-JLB (S.D. CA)

(Woodrow & Peluso appointed co-lead Settlement Class Counsel in TCPA settlement

providing option of $750 cash or $1,100 in storage certificates) (final approval granted

August 23, 2016); • Sherry Brown and Ericka Newby v. Rita's Water Ice Franchise Company, LLC, 2:15-cv-03509-TJS (E.D. PA) ("all in" non-reversionary $3,000,000 settlement fund for

text messages) (final approval granted March 20, 2017);

• Morris et al v. SolarCity, Inc. 3:15-cv-05107 (N.D. CA) (JPA with counsel on $15

million common fund TCPA settlement).

Further, while a Partner with his prior law firm, Woodrow & Peluso attorney Steven

Woodrow was appointed interim co-lead class counsel in a TCPA class action against Nationstar

Mortgage, LLC (see Jordan et al v. Nationstar Mortgage LLC, 3:14-cv-00787-WHO) and led

TCPA litigation that resolved favorably against Bankrate Inc., and Carfax.com. Mr. Woodrow

was also involved in the TCPA settlement reached in Weinstein v. The Timberland Co. et al. (N.D. Ill.), a text messaging class action featuring 40,000 unauthorized messages, and was part

of the appellate strategy team that secured the landmark decision in Satterfield v. Simon &

Schuster, Inc., 569 F.3d 946 (9th Cir. 2009), the first federal appellate decision to affirm that text

messages are covered as “calls” under the TCPA.

FCRA Class Actions

The second sub-focus within the firm’s class action practice consists of cases under the

Fair Credit Reporting Act (“FCRA”), which regulates the procurement and use of consumer

reports by employers when they make hiring/firing/pay decisions. To date, the firm has

successfully represented clients in putative class actions against Terminix, ServiceMaster,

TrueBlue Inc./Labor-Ready Mid-Atlantic, FedEx, Tyler Staffing Services, Inc., Great Lakes

Wine & Spirits, Freeman Webb, Inc., and others. This includes Woodford v. World Emblem

1:15-cv-02983-ELR, an FCRA settlement providing between $315 and $400 to claimants (final

approval granted January 23, 2017).

Banking and Financial Institutions Class Actions

Our attorneys have substantial experience representing consumers in class action litigation

involving national banking associations and other financial institutions. Meaningful

representations include:  Schulken v. Washington Mut. Bank, No. 09-CV-02708-LHK, 2012 WL

28099, at *15 (N.D. Cal. Jan. 5, 2012). Attorney Steven Woodrow secured

prior firm’s appointment as Class Counsel from Judge Lucy Koh in class

action challenging JPMorgan Chase Bank, N.A.’s suspension of former

WaMu home equity line of credit accounts. Case settled with Mr.

Woodrow’s appointment as co-lead settlement class counsel.
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 In re JPMorgan Chase Bank, N.A. Home Equity Line of Credit Litigation, MDL No. 2167. Attorney Steven Woodrow helped secure transfer by the

Judicial Panel on Multidistrict Litigation to the Northern District of Illinois

and appointment of prior firm as interim class counsel. Attorney Woodrow

also negotiated and was also appointed co-lead settlement class counsel in

settlement projected to restore between $3 billion - $5 billion in credit to

affected borrowers in addition to cash payments.  Hamilton v. Wells Fargo Bank, N.A., 4:09-cv-04152-CW (N.D. Cal.).

Attorney Steven Woodrow served as co-lead settlement counsel in class

action challenging Wells Fargo’s suspensions of home equity lines of credit.

Nationwide settlement restored access to over $1 billion in credit and

provided industry leading service enhancements and injunctive relief.  In re Citibank HELOC Reduction Litigation, 09-CV-0350-MMC (N.D.

Cal.). Attorney Steven Woodrow was appointed interim co-lead counsel

and settlement class counsel in class actions challenging Citibank’s

suspensions of home equity lines of credit. The settlement was estimated to

have restored over $650,000,000 worth of credit to affected borrowers.  Vess v. Bank of America, N.A. 10cv920–AJB(WVG) (S.D. Cal.). Attorney

Steven Woodrow negotiated class action settlement with Bank of America

challenging suspension and reduction of home equity lines of credit.  Wigod v. Wells Fargo, No. 10-cv-2348 (N.D. Ill.). Steven Woodrow

secured the first appellate decision in the country recognizing the right of

homeowners to sue under state law to enforce HAMP trial plan agreements.

Attorney Steven Woodrow was appointed co-lead settlement counsel

providing loan modifications and cash payments to affected borrowers.

General Consumer Protection Class Actions

Woodrow & Peluso attorneys have additionally successfully prosecuted and resolved

countless class action suits against other companies for a range of consumer protection issues. For

example, Woodrow & Peluso filed the first class action in the Country to challenge the marijuana

industry’s use of certain allegedly dangerous fungicides and pesticides and were the first lawyers

to bring class actions (against the Colorado Rockies Baseball Club and Kroenke Sports &

Entertainment, LLC) seeking to enforce the Colorado Consumer Protection Act, § 6-1- 718 et seq., which prohibits owners of entertainment venues from imposing restrictions on the resale of tickets.

The firm has also brought and litigated class actions against hospitals for their use of

“chargemaster” billing rates and are presently engaged in litigation against Southwest Airlines

related to its “Companion Pass” program.

Woodrow & Peluso LLC has also brought claims against major food manufacturers and

distributors for falsely advertising certain products as “All Natural” and “Made in U.S.A.” Our

attorneys also have experience litigating class claims regarding missing or misappropriated

“bitcoins.” Woodrow & Peluso also brought the first class action in Colorado against cannabis
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growers for their use of unapproved and harmful pesticides.

2. COMMERCIAL LITIGATION

As small business owners, we understand and appreciate the challenges that new

companies face as they strive to make headway in the market. Our attorneys regularly counsel

small to medium-sized businesses and have represented such companies in a wide range of general

commercial litigation matters including partnership and business disputes, breaches of contracts

and term sheets, and claims charging company managers and members of breach of fiduciary duty,

breach of contract, fraud, and fraudulent/preferential transfers. We regularly advise clients on

matters and contracts involving millions of dollars, and our attorneys have successfully represented

businesses and other entities in mediations, arbitrations, and trial.

3. APPEALS

Our attorneys have substantial experience handling appeals at both the state and federal

level. Representative appeals worked on predominately by our attorneys include:  Wigod v. Wells Fargo Bank, N.A., 673 F.3d 547 (7th Cir. 2012). Attorney

Steven Woodrow briefed and argued this appeal resulting in the first

federal appellate decision holding that banks may be sued under state law

for violations of the federal government’s Home Affordable Modification

Program. The opinion has been cited over 1,300 times by courts, litigants,

and commentators throughout the Country and is widely regarded as the

leading authority on the rights and obligations of HAMP servicers and

borrowers.  Robins v. Spokeo, 742 F.3d 409 (9th Cir. 2014). Attorney Steven Woodrow

argued a federal appeal reversing dismissal and upholding consumer rights

under the Fair Credit Reporting Act against one of the nation’s largest

online data aggregators regarding whether a plaintiff who does not suffer

tangible pecuniary loss may still show legal harm to satisfy Article III

standing. The case was reversed on writ of certiorari to the United States

Supreme Court (argued by different attorneys).  Equity Residential Properties Mgmt. Corp. v. Nasolo, 364 Ill. App. 3d 26,

28, 847 N.E.2d 126, 128 (2006). Attorney Steven Woodrow helped author

the winning brief in this landmark landlord/tenant appeal defining the

requirements for constructive service and due process for Illinois evictions

under the Illinois Forcible Entry and Detainer Act. 735 ILCS 5/9–107 et

seq.  Fuentes v. Kroenke Sports & Entertainment, LLC, Case No. 2014CV32619.

Woodrow & Peluso appealed grant of summary judgment in favor of

defendant finding that the Colorado Consumer Protection Act, 6-1-701 et
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seq. does not allow for class actions. Case settled prior to the resolution of

the appeal.

OUR ATTORNEYS

At present, our firm consists of 3 attorneys whose relevant experience is set forth below.

STEVEN LEZELL WOODROW has over a decade of experience advising consumers and small

businesses in high stakes litigation.

Steven briefed and delivered the winning argument in the landmark federal appellate court decision

Wigod v. Wells Fargo Bank, N.A., 673 F.3d 547 (7th Cir. 2012) holding banks accountable for

violations of the federal Home Affordable Modification Program. The opinion is widely regarded

as the leading authority on the rights and obligations of HAMP servicers and borrowers. Steven

also delivered the winning oral argument in Robins v. Spokeo, 742 F.3d 409 (9th Cir. 2014), a

federal appeal upholding consumer rights under the Fair Credit Reporting Act against one of the

nation’s largest online data aggregators. The case and the Supreme Court decision that ultimately

reversed it (and now the Ninth Circuit's decision to re-affirm its prior finding of Article III

standing) present some of the most widely-litigated issues in class action practice today.

Mr. Woodrow was appointed lead class counsel in litigation against JPMorgan Chase Bank,

N.A. challenging the bank’s 4506-T HELOC suspension program and was appointed lead

settlement class counsel in other HELOC suspension litigation against Wells Fargo Bank, N.A.,

Citibank, N.A., Chase, Bank of America, N.A. and PNC Bank.

Mr. Woodrow also led the legal team that secured a preliminary injunction freezing the U.S. assets

of Mark Karpeles, the former head of the failed Bitcoin exchange known as Mt. Gox, as well as

an order compelling Mr. Karpeles to personally appear in the United States for a

deposition in connection with Mt. Gox’s Chapter 15 bankruptcy case in Dallas Texas.

Steven has also litigated putative class actions under the Telephone Consumer Protection Act, and

courts have appointed him to serve as class counsel in nationwide settlements against cellphone

companies, aggregators, and mobile content providers related to unfair billing practices, including

Paluzzi v. Cellco Partnership, Williams v. Motricity, Inc., and Walker v. OpenMarket Inc. Steven has also served as an Adjunct Professor of Law at the Illinois Institute of

Technology Chicago-Kent College of Law, where he co-taught a seminar on class actions. Prior

to founding Woodrow & Peluso, Steven was a partner at prominent class action technology firm

in Chicago.

Before that, he worked as a litigator at a Chicago boutique where he tried and arbitrated a range of

consumer protection, landlord tenant, and real estate matters.

EDUCATION

Chicago-Kent College of Law, J.D., High Honors, 2005

The University of Michigan-Ann Arbor, B.A, Political Science, with Distinction, 2002
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ADMISSIONS

State of Illinois (2005)

State of Colorado (2011)

United States Court of Appeals for the Seventh Circuit

United States Court of Appeals for the Ninth Circuit

United States District Court, Northern District of Illinois

United States District Court, District of Colorado

United States District Court, Eastern District of Michigan

United States District Court, Western District of Michigan

United States District Court, District of New Mexico

PATRICK H. PELUSO specializes in plaintiff-side consumer class actions.

With a true passion for protecting consumers and their rights, Patrick aggressively pursues class

action lawsuits against companies who violate those rights.

Through these lawsuits, he is able to force law-breaking companies to compensate the people they

have harmed and correct their future practices. Patrick possesses the skills, strategic vision, and

moxie to achieve excellent results for the people he represents. He has experience working with a

broad range of consumer protection laws including the Fair Credit Reporting Act, the Telephone

Consumer Protection Act, and various state consumer protection and consumer fraud statutes.

Patrick received his law degree from the University of Denver, Sturm College of Law where he

was Editor-in-Chief of an academic journal. During law school, Patrick worked with a leading

consumer class action law firm and held legal internships with a federal administrative judge and

the legal department of a publicly traded corporation. Before law school, Patrick attended New

York University, where he graduated with a B.S. and played on the school’s club baseball team.

Patrick grew up in Baltimore, Maryland and now resides in Denver, Colorado.

EDUCATION

University of Denver, J.D. 2014

New York University, B.S.

ADMISSIONS

State of Colorado (2014)

United States District Court, District of Colorado

United States District Court, District of New Mexico

United States District Court, Eastern District of Michigan

United States District Court, Northern District of Illinois

United States District Court, Western District of Wisconsin
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TAYLOR TRUE SMITH focuses his practice on consumer class actions.

Throughout his life and career, Taylor has developed a passion for consumer advocacy. By

pursuing class actions on behalf of consumers, Taylor can give consumers not just a voice but

also a seat at the bargaining table.

Taylor received his law degree from the Creighton University School of Law. During law school,

he interned with the South Dakota Supreme Court. Prior to beginning law school, Taylor

attended South Dakota State University where he earned a B.S. in Economics.

Taylor was raised in Fort Pierre, South Dakota and currently resides in Denver, Colorado.

Education

Creighton University School of Law, J.D. Cum Laude 2017

South Dakota State University, B.S. Magna Cum Laude 2013

Admissions

State of Colorado (2017)

United States District Court, District of Colorado

United States District Court, Eastern District of Michigan

United States District Court, Northern District of Illinois