EXHIBIT Q 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

IN RE: TIKTOK, INC., 

CONSUMER PRIVACY 

LITIGATION 

This Document Relates to All Cases 

MDL No. 2948 

Master Docket No. 20-cv-4699 

Judge John Z. Lee 

Magistrate Judge Sunil R. Harjani 

DECLARATION OF JAMES B. ZOURAS IN SUPPORT OF PLAINTIFFS’ PETITION 

FOR AWARD OF ATTORNEYS’ FEES FILED ON 

BEHALF OF STEPHAN ZOURAS, LLP. 

 I, James B. Zouras, declare and state as follows: 

1. I am a Founder and Partner of the law firm of Stephan Zouras, LLP. My firm’s 

resume is attached hereto as Exhibit 1. I submit this Declaration in support of Plaintiffs’ petition 

for an award of attorneys’ fees and reimbursement of costs and expenses in connection with 

services rendered and expenses incurred by my firm in connection with this litigation. 

2. My firm has acted as counsel to Plaintiffs and Plaintiffs’ classes in this action. 

During the period from case inception through October 31, 2020 (the first reporting period 

pursuant to the Court’s Case Management Order No. 4: Common Benefit Fee and Expense 

Protocol [Dkt. 105], my firm conducted the following activities for the common benefit of 

Plaintiffs: Investigation and research into the technological function, capabilities and capacities 

of the Tik Tok App, including expert retention, consultation and investigation into how the app 

functions in both the United States and China; legal and factual research into the potential claims 

and defenses; research into the corporate structure of the various defendants and potential 

defendants (including individuals); as a member of the discovery committee, drafted discovery 

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requests including a deposition on written questions; meetings, emails and discussions with CoLead and other plaintiff counsel on litigation and potential mediation and settlement strategy 

which, as a member of the comparable settlements committee, included research and consultation 

with our firm’s database to analyze comparable BIPA settlements; assisted with drafting the 

consolidated complaint. The total number of hours expended on this litigation by my firm from 

case inception through October 31, 2020, is 337.8 hours. The total lodestar for my firm in this 

time period is $188,602.50. 

3. For the time period November 1, 2020 through February 28, 2022, and at the 

request of Plaintiffs’ Co-Lead Counsel, my firm conducted the following activities for the common 

benefit of Plaintiffs: At the request of Co-Lead Counsel, engaged in settlement negotiations as 

counsel for the Illinois Subclass with counsel for the Nationwide Class with respect to a proposed 

allocation of the Settlement Fund to ensure the allocation of the Settlement Fund was fair to the 

Illinois Subclass. In connection with this activity, consulted, emailed and met with Co-Lead 

Counsel on the results of our respective factual and legal investigation and research, the factual 

and procedural history of the litigation, the claims and defenses (both substantive and procedural), 

as well as the respective interests of the Illinois Subclass and Nationwide Class; reviewed all 

publicly filed pleadings in this case; reviewed the Settlement Agreement and addendum, mediation 

briefs, declarations, and other confidential work product addressing issues in the litigation, 

including attorney research on the strength and weaknesses of the Plaintiffs’ claims, settlements 

and claims rates in comparable privacy cases, and relevant case law on the VPPA and CPPA; 

engaged in at least 10 meetings with counsel for the Nationwide Class, along with phone calls and 

emails; exchanged and analyzing allocation models; ultimately reaching an agreement on 

allocation as memorialized in a declaration; reviewed the preliminary approval filings, reviewed 

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objections and attended the preliminary approval hearing. The total number of hours expended on 

this litigation by my firm from for the time period November 1, 2020 through February 28, 2022, 

is 127.3. The total lodestar for my firm in this time period is $68,305.00. 

4. The total number of hours expended on this litigation by my firm from case 

inception through February 28, 2022, is 454.9 hours. The total lodestar for my firm is 

$255,242.50. My firm’s lodestar figures are based on the firm’s historic hourly billing rates. The 

hourly rates for the partners, associate attorneys and professional support staff in my firm are the 

same as the usual and customary hourly rates charged for their services in contingent billable 

matters. The total number of hours was determined by the examination of contemporaneous, daily 

time records regularly prepared and maintained by my firm and which have been provided to CoLead Counsel for their review. 

5. Attached hereto as Exhibit 2 is a detailed summary indicating the amount of time 

spent by the partners, attorneys and other professional support staff of my firm who have been 

involved in this litigation, and the lodestar calculation is based on my firm’s historic hourly billing 

rates from case inception through February 28, 2022. 

6. As detailed in Exhibit 3, my firm has incurred a total of $1,803.11 in unreimbursed 

expenses during the period from case inception through February 28, 2022. These expenses do not 

include my firm’s assessment payments to the common cost litigation fund maintained by CoLead Counsel. 

7. The expenses incurred in this action are reflected on the books and records of my 

firm. These books and records are prepared from expense vouchers, check records and other 

source materials and represent an accurate recordation of the expenses incurred. 

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 I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

 Executed on this 25th day of March 2022 at Chicago, Illinois. 

 

 /s/ James B. Zouras 

 James B. Zouras 

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Exhibit 

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FIRM PROFILE

STEPHAN ZOURAS, LLP is a national law firm which concentrates on helping clients in complex class and individual 

litigation. The firm is widely recognized for its vigorous advocacy, skill, integrity and experience litigating wage and hour 

and other employment disputes, mass torts and catastrophic personal injury, consumer protection, privacy, 

cybersecurity, products liability and other complex litigation. Courts routinely appoint us as lead counsel in high-stakes, 

groundbreaking, rapidly-developing areas with far-reaching impact. Our attorneys have testified before legislative 

bodies and worked on legislation designed to protect worker’s rights. 

Our Chicago-based firm is recognized for its leadership, its zealous, thorough and efficient prosecution of class actions, 

and for achieving outstanding results at both the trial and appellate levels throughout the United States. The firm's two 

founding partners, James B. Zouras and Ryan F. Stephan, have successfully prosecuted claims ranging from individual 

wrongful death and other catastrophic injury cases to complex, multi-district class and collective actions which have 

collectively resulted in a recovery of more than $250,000,000 for hundreds of thousands of individuals. Stephan Zouras, 

LLP has “substantial class action experience [and] have secured multi-million-dollar class recoveries....” Bhattacharya v. 

Capgemini North America, Inc., 324 F.R.D. 353, 363 (N.D. Ill. 2018) (Kennelly, J.) 

PRINCIPAL ATTORNEYS

JAMES B. ZOURAS is a founding principal of Stephan Zouras, LLP. Dedicating his entire professional career to 

combating corporate abuse and injustice, Jim has helped thousands of people recover tens of millions of dollars in 

damages in individual and class actions arising under federal wage and hour laws including the Fair Labor Standards 

Act ("FLSA") and comparable state wage laws, other complex litigation and catastrophic personal injury. Jim has been 

appointed lead or co-lead counsel on dozens of contested class actions throughout the United States. He has 

successfully tried over a dozen jury trials and argued over 14 appeals as lead appellate counsel before federal and state 

appellate courts. In 2000, Jim was named among the Chicago Daily Law Bulletin's "Top 40 Lawyers Under Age 40," one 

of the youngest lawyers ever bestowed that honor. Jim and his cases have been profiled by numerous media outlets 

including the Chicago Tribune, the Chicago Sun-Times, Bloomberg BNA, WVON radio, Billboard Magazine and TMZ. 

Jim has also been interviewed by CBS Consumer Watch. Jim is frequently invited as a speaker at national class action 

litigation seminars. Jim is a 1995 graduate of DePaul University College of Law, where he served as Editor of the Law 

Review and graduated in the top 10% of his class. 

RYAN F. STEPHAN is a founding principal of Stephan Zouras, LLP. Throughout his career, Ryan has been a passionate 

advocate for employee rights, and has helped thousands of clients recover damages in unpaid overtime, employment 

disputes, business litigation, products liability and personal injury cases. Ryan has successfully tried cases to verdict 

including obtaining a $9,000,000 verdict on behalf of 200 employees who were misclassified and denied overtime pay. 

Ryan has also served as lead or co-lead counsel on dozens of complex class and collective action cases involving wage 

and hour matters and has helped recover damages for tens of thousands of wronged employees. In these cases, Ryan 

has helped establish precedent in wage and hour law, forced major corporations to change unlawful employment 

practices and helped recover tens of millions of dollars in unpaid wages for his clients. Ryan and his cases have been 

profiled by numerous media outlets including Good Morning America, Fortune, ESPN, Fox News, The Guardian, The 

New York Times, Think Progress, USA Today and Vice Sports. Ryan is a 2000 graduate from Chicago Kent College of 

Law. 

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Ryan and Jim are admitted to the Supreme Court of the United States, the Seventh Circuit Court of Appeals, and the 

Trial Bar of the United States District Court for the Northern District of Illinois. In addition, they have been admitted pro 

hac vice to prosecute class actions in the District of Alaska, the District of Arizona, the District of Columbia, the Northern 

and Southern Districts of California, the Southern and Eastern Districts of New York, the District of New Jersey, the 

Eastern and Middle Districts of Pennsylvania, the Northern and Western Districts of North Carolina, the Superior Court 

for the State of California, the Central District of Illinois, the Southern District of Indiana, the District of Minnesota, the

Eastern District of Michigan, the Eastern and Western Districts of Missouri, the District of Maryland, the Southern District 

of Ohio, the Northern, Middle and Southern Districts of Florida, the Northern District of Georgia, the Western District of 

Kentucky, the District of Maryland, the Northern District of Texas, the District of Massachusetts, the District of Minnesota, 

the First Judicial District of Pennsylvania, the Western District of Washington and the Southern and Northern Districts 

of Iowa. 

In every consecutive year since 2009, Chicago Magazine's Super Lawyer Section selected both Jim and Ryan as two of 

the top attorneys in Illinois, a distinction given to no more than 5% of the lawyers in the state. 

PARTNERS 

ANDREW C. FICZKO is a partner of Stephan Zouras, LLP. A tireless fighter for working people, Andy has spent his entire 

professional career litigating on behalf of employees in class and collective actions nationwide. Andy has helped 

thousands of clients recover damages in cases involving unpaid minimum and overtime wages and other benefits. Andy 

served as the second chair in two major federal jury trials to verdict on behalf of Plaintiffs in wage and hour matters and 

one state jury trial to verdict on behalf of Plaintiffs in a breach of contract matter. A 2009 graduate from Drake University 

Law School in 2009, Andy is admitted to the Trial Bar of the United States District Court for the Northern District of 

Illinois has been admitted pro hac vice to the District of Alaska, the Central and Northern Districts of California, the 

District of Columbia, the Northern District of Georgia, the Southern District of Indiana, the Southern District of New 

York, the Southern and Northern Districts of Iowa, the District of Massachusetts, the Western District of Missouri, the 

Middle and Western Districts of North Carolina, the Southern District of Ohio, the Eastern and Middle Districts of 

Pennsylvania, the Northern and Southern Districts of Texas, and the Western District of Washington. In every 

consecutive year since 2014, Andy has been recognized by Chicago Magazine’s Super Lawyer section as a Rising Star, a 

distinction given to no more than 2.5% of Illinois lawyers. 

TERESA M. BECVAR is a partner of Stephan Zouras, LLP. A steadfast advocate for individual rights, Teresa has helped 

thousands of clients hold corporations accountable in employment and consumer protection cases. Teresa has extensive 

experience in a wide range of employment cases, including wage and hour class and collective actions and employment 

discrimination. Teresa is a 2013 graduate of Chicago-Kent College of Law, where she served as Editor of the Law Review 

and graduated in the top 15% of her class. Teresa is admitted to practice in Illinois and has been admitted pro hac vice 

to the Eastern and Southern Districts of New York, the Western District of Washington, the Middle District of Florida 

and the Central District of California, the District of Arizona, the Middle District of Pennsylvania, the District of Colorado,

the District of New Mexico, the Western District of North Carolina, and the Middle District of Tennessee. In every 

consecutive year since 2016, Teresa has been recognized by Chicago Magazine’s Super Lawyer section as a Rising Star, 

a distinction given to no more than 2.5% of Illinois lawyers. 

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CATHERINE T. MITCHELL is a partner of Stephan Zouras, LLP who graduated from UIC John Marshall Law School in 

2015. Katie litigates on behalf of Stephan Zouras, LLP’s clients in both class action and individual litigation, representing 

people in a wide-range of legal disputes, including unpaid wages, employee misclassification, mass torts, antitrust, and 

consumer fraud. Catherine is an active member of the Women’s Bar Association of Illinois and the Young Lawyers Society 

of the Chicago Bar Association, and served as a Chapter Editor for the Second Edition of BNA’s Age Discrimination in 

Employment Act Treatise. Katie is admitted to practice in Illinois, the District of Colorado, the Eastern District of 

Wisconsin and has been admitted pro hac vice to the Southern and Eastern Districts of New York, the Middle District of 

Florida, the Southern District of Iowa, the Northern District of California, the District of Arizona, the District of New 

Mexico, the Eastern District of Pennsylvania, and the Eastern and Western Districts of North Carolina. Katie earned her 

Bachelor’s Degree from Saint Mary’s College where she was a member of the Dean’s list and served as a Member 

Counselor in the Business Enterprise Law Clinic. Katie is currently an active member of the Women’s Bar Association as 

well as a Director on UIC John Marshall Law School Alumni Association’s Board of Directors. 

HALEY R. JENKINS is a partner of Stephan Zouras, LLP who graduated cum laude from Chicago-Kent College of Law in 

2016. Haley litigates on behalf of Stephan Zouras, LLP’s clients in both class action and individual litigation. A spirited 

advocate, Haley represents clients in legal disputes involving unpaid wages, employee misclassification, and 

whistleblower actions. As lead attorney in one of the first in-person jury trials for unpaid wages following the COVID-19 

pandemic, Haley obtained a verdict and corresponding six-figure damages award on behalf of one of her clients. She is 

currently a member of the legal team advocating for clients’ biometric privacy rights in cutting-edge cases against 

employers and biometric device manufacturers that unlawfully collect, store, use and disseminate employees’ and 

consumers’ biometrics data. Haley is admitted to the Trial Bar of the United States District Court for the Northern District 

of Illinois and the District of Colorado. She has also been admitted pro hac vice to the Middle and Eastern Districts of 

Pennsylvania, and the Eastern District of New York. Haley graduated from the University of Illinois at Urbana-Champaign 

in 2013 where she majored in English. 

ASSOCIATE ATTORNEYS 

ANNA M. CERAGIOLI earned her Juris Doctor from Chicago-Kent College of Law where she was named to the Dean’s 

List and elected President of the Moot Court Honor Society. She was one of only twelve graduating students inducted 

into the Chicago-Kent Bar & Gavel Society. Anna is a skilled and dedicated advocate for individuals and groups of people 

who have been injured, deprived of earned wages or otherwise mistreated by employers. She has worked tirelessly on 

an array of individual and class actions lawsuits involving unpaid wages, employee misclassification, tip-pool violations, 

retaliation, RICO violations, and unlawful credit checks. Anna is admitted to the Trial Bar of the United States District 

Court for the Northern District of Illinois. She has also been admitted pro hav vice to the Eastern District of New York 

and the Eastern District of Pennsylvania. Anna received her undergraduate degree from Marquette University where she 

double-majored in Writing Intensive English and Politics in Law. 

PAIGE L. SMITH joined the Stephan Zouras team with a passion and dedication for vindicating Illinois citizen’s rights 

under the Illinois Biometric Privacy Act (BIPA). Paige graduated cum laude from Chicago-Kent College of Law, where she 

was a member of the Dean’s List, and served as the Executive Notes & Comments Editor of the Chicago-Kent Law 

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Review. Since joining the firm, Paige has assisted in trailblazing actions involving BIPA, consumer breach contract, unpaid 

wages, employee misclassification, employment discrimination, and retaliatory discharge claims. Paige earned her 

undergraduate degree from the University of Wisconsin-Madison, where she graduated with Honors in Liberal Arts, with 

a degree in Political Science. 

OF COUNSEL 

DAVID J. COHEN, a highly skilled and successful class-action attorney, joined Stephan Zouras, LLP in April 2016 and 

manages our Philadelphia office. Dave has spent his entire career fighting to protect the rights of thousands of 

employees, consumers, shareholders, and union members. Before joining Stephan Zouras, Dave worked on, and ran, 

dozens of significant antitrust, consumer, employment and securities matters for four highly-regarded Philadelphia 

firms. Before joining the private sector, Dave completed a unique clerkship with the Hon. Stephen E. Levin in the 

Philadelphia Court of Common Pleas, during which he not only helped to develop a respected and efficient system for 

the resolution of the Court’s class action cases, but also contributed to several well-regarded works on class actions. 

Dave earned a J.D. from the Temple University School of Law in 1994. While attending law school, Dave was awarded 

the Barristers Award for excellence in trial advocacy and worked as a teaching assistant for Hon. Legrome Davis (E.D. 

Pa.) as part of Temple’s award-winning Integrated Trial Advocacy program. Dave graduated with honors from the 

University of Chicago in 1991. 

Dave is admitted to practice in the United States Court of Appeals for the Third Circuit, the United States Court of 

Appeals for the Sixth Circuit, the United States District Court for the Eastern District of Pennsylvania, the United States 

District Court for the Middle District of Pennsylvania, the United States District Court for the Western District of 

Pennsylvania, the United States District Court for the District of New Jersey and the state courts of Pennsylvania and 

New Jersey. He is a member of the American and Philadelphia Bar Associations. 

REPRESENTATIVE TRIALS, VERDICTS AND JUDGMENTS

Meadows, et al. v. NCRCorporation 7/09/21 - Trial Court Judgment 

No. 16-cv-06221 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP won a jury verdict awarding over $225,000 in damages to an ATM service worker deprived of 

overtime pay in violation of the FLSA and IMWL. On an issue of first impression, the Court held the plaintiff is entitled 

to both liquidated damages under the FLSA and statutory damages under the IMWL. 

Retaliation Arbitrations (Captions Redacted for Confidentiality) 2/2019 & 9/2020 – Arbitration Judgment 

Stephan Zouras, LLP achieved favorable arbitration awards in two separate AAA actions on behalf of former workers 

who were fired for filing a lawsuit challenging unpaid overtime practices, in violations of the FLSA and IMWL. Together, 

the employees received damages exceeding $400,000.00. 

Ray v. DISH Network 

No. 01-15-0003-4651 (AAA Arbitration) 3/17/19 – Arbitration Judgment

Final approval was awarded in the amount of $3,250,000.00 to thousands of Colorado inside sales associates who were 

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not paid minimum wage for all hours worked and were not paid proper overtime compensation for hours worked in 

excess of 40 hours per week. 

Franco, et al. v. Ideal Mortgage Bankers, d/b/a Lend America 12/14/17 – Trial Court Judgment 

No. 07-cv-3956 (United States District Court for the Eastern District of New York) 

The Court entered a $15.2 million judgment on behalf of several hundred loan officers who were deprived of minimum 

wages and overtime in violation of federal and state law. 

Frisari v. DISH Network 8/25/16 – Arbitration Judgment 

No. 18-160-001431-12 (AAA Arbitration) 

The Arbitrator certified and granted final judgment in excess of seven figures for a class of over 1,000 New Jersey inside 

sales associates who performed work before and/or after their shifts without pay and were not paid the proper overtime 

rate when they worked in excess of 40 hours a week. 

Huskey v. Ethicon Inc. 9/10/14 – Jury Verdict 

No. 2:12-cv-05201 (United States District Court for the Southern District of West Virginia) 

Stephan Zouras, LLP helped secure a $3,270,000.00 jury verdict in one of the bell-weather trial cases in the multi-district 

litigation against Johnson & Johnson’s Ethicon unit for defective design, failure to warn and negligence related to 

transvaginal mesh device. 

Lee v. THR 5/22/14 – Trial Court Judgment 

No. 12-cv-3078 (United States District Court for the Central District of Illinois) 

As a result of the efforts of class counsel Stephan Zouras, LLP, the Court entered a judgment for a class of employees 

given job titles such as "Buyers," "Auditors" and "Managers" for unpaid overtime in the sum of $12,207,880.84. 

Vilches et al. v. The Travelers Companies, Inc. 12/12/12 - Arbitration Judgment 

No. 11-160-000355-11 (American Arbitration Association) 

Following a contested evidentiary hearing, Stephan Zouras, LLP secured a significant monetary award on behalf of a 

group of insurance appraiser employees seeking unpaid earned overtime under the FLSA. 

Kyriakoulis, at al. v. DuPage Health Center 11/8/12 - Jury Verdict 

No. 10-cv-7902 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP achieved a favorable jury verdict on behalf of several medical assistants deprived of minimum and 

overtime wages in violation of federal and Illinois law. 

Smith v. Safety-Kleen Systems, Inc. 7/11/12 - Jury Verdict

No. 10-cv-6574 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP achieved a favorable jury verdict on behalf of a chemical handler deprived of overtime wages in 

this donning and doffing action brought under the FLSA. 

Wong v. Wice Logistics 1/30/12 - Jury Verdict

No. 08 L 13380 (Circuit Court of Cook County, Illinois) 

Stephan Zouras, LLP recovered unpaid commissions and other damages for Plaintiff based on her claims under the 

Illinois Wage Payment and Collection Act.

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Daniels et al. v. Premium Capital Financing 10/18/11 - Jury Verdict

No. 08-cv-4736 (United States District Court for the Eastern District of New York) 

Stephan Zouras, LLP was appointed lead class and trial counsel and achieved a jury verdict in excess of $9,000,000.00 

on behalf of over 200 loan officers who were deprived of minimum wages and overtime pay. 

Ferrand v. Lopas 5/22/01 - Jury Verdict

No. 00 L 2502 (Circuit Court of Cook County, Law Division, State of Illinois) 

Jury verdict in excess of available liability insurance policy limits entered in favor of seriously-injured pedestrian, resulting 

in liability against insurance carrier for its bad faith refusal to tender the policy limits before trial. 

REPRESENTATIVE RESOLVED CLASS AND COLLECTIVE ACTIONS 

Courts nationwide have appointed the firm as lead or co-lead counsel in numerous class and collective actions 

in which they have collectively secured over one hundred million dollars in verdicts and settlements including: 

 

Bledsoe, et al. v. LHC Group, Inc. 2/08/22 – Final Approval 

No. cv-18-02863 (United States District Court for the District of Arizona) 

and, 

George, et al. v. LHC Group 

No. cv-21-01402 (United States District Court for the District of Arizona) 

Stephan Zouras, LLP settled for six figures on behalf of employees who were wrongfully denied proper premium 

overtime pay for all hours worked beyond 40 in given workweeks as required by the Fair Labor Standards Act (“FLSA”).

Krzyzanowski, et al. v. Brunch Café, et al. 2/02/22 – Final Approval 

No. 19-cv-07427 (United States District Court for the Northern District of Illinois)

Stephan Zouras, LLP recovered $425,000 on behalf of servers forced to participate in an illegal “tip pool”, violating the 

Fair Labor Standards Act (“FLSA”) and the Illinois Minimum Wage Law (“IMWL”). 

Toor, et al. v. CoreCentric Solutions, Inc. 1/25/22 – Final Approval 

No. 2019-CH-000989 (Circuit Court of DuPage County, Chancery Division, State of Illinois) 

Final approval was granted in a six-figure class settlement on behalf of employees whose rights were violated under the 

Biometric Information Privacy Act (“BIPA”). 

Peatry, et al. v. Bimbo Bakeries USA, Inc. 1/12/22 – Final Approval 

No. 19-cv-02942 (United States District Court for the Northern District of Illinois) 

The Court granted final approval in a six-figure class settlement on behalf of employees whose rights were violated 

under the Biometric Information Privacy Act (“BIPA”). 

Ripper, et al. v. Area Disposal Service, Inc. et al. 11/16/21 – Final Approval 

No. 2020-CH-00124 (Circuit Court of Peoria County, Chancery Division, State of Illinois) 

The Court granted final approval of more than half a million dollar settlement on behalf of hundreds of employees 

whose rights were violated under the Biometric Information Privacy Act (“BIPA”).

O’Sullivan, et al. v. All Star Management, Inc. 9/02/21 – Final Approval 

No. 19-CH-11575 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

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Final approval was granted in a $2 million class settlement on behalf of thousands of employees whose rights were 

violated under the Biometric Information Privacy Act (“BIPA”). 

Sanchez, et al. v. Visual Pak 8/10/21 – Final Approval 

No. 18-CH-02651 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Stephan Zouras, LLP settled for approximately $1.1 million on behalf of employees whose rights were violated under 

the Biometric Information Privacy Act (“BIPA”).

Civcon v. Services, Inc. v. Accesso Services, LLC 7/08/21 – Final Approval 

No. 20-cv-01821 (United States District Court for the Northern District of Illinois) 

Stephan Zouras secured a $500,000.00 settlement in a first-of-its-kind RICO class action alleging that a building 

management company in the Chicago Loop conspired with major trade unions to forbid its tenants from hiring nonunion trade workers. 

Ramos, et al. v. BOX Acquisitions, LLC. 8/05/21 – Final Approval 

No. 20-CH-03887 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Stephan Zouras, LLP secured over $1.3 million for hundreds of employees whose rights were violated under the 

Biometric Information Privacy Act (“BIPA”). 

Van Jacobs, et al. v. New World Van Lines, Inc. 7/07/21 – Final Approval 

No. 19-CH-02619 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

The Court granted final approval in a six-figure class settlement on behalf of employees whose rights were violated 

under the Biometric Information Privacy Act (“BIPA”). 

Liu, et al. v. Four Seasons Hotels, Ltd., et al. 6/30/21 – Final Approval 

No. 17-CH-14949 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Stephan Zouras, LLP secured half a million dollar settlement on behalf of hotel employees whose rights were violated 

under the Biometric Information Privacy Act (“BIPA”). 

Bedford, et al. v. Lifespace Communities, Inc. 5/12/21 – Final Approval 

No. 20-cv-04574 (United States District Court for the Northern District of Illinois) 

The Court granted final approval of more than half a million dollar settlement on behalf of employees whose rights were 

violated under the Biometric Information Privacy Act (“BIPA”). 

Heard, et al. v. THC – Northshore, Inc., et al. 5/05/21 – Final Approval 

No. 17-CH-16918 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

As lead counsel, Stephan Zouras secured a $2.25 million settlement for employees whose rights were violated under the 

Biometric Information Privacy Act (“BIPA”). 

Thome, et al. v. Novatime Technology, Inc. 3/08/21 – Final Approval 

No. 19-cv-06256 (United States District Court for the Northern District of Illinois) 

As lead counsel, Stephan Zouras secured over $14.1 million for thousands of employees whose rights were violated 

under the Biometric Information Privacy Act (“BIPA”). 

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Kusinski, et al. v. ADP, LLC. 2/10/21 – Final Approval 

No. 17-CH-12364 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

As co-counsel, Stephan Zouras, LLP secured a record-breaking $25 million settlement on behalf of employees whose 

rights were violated under the Biometric Information Privacy Act (“BIPA”). 

Trayes, et al. v. Mid-Con Hospitality Group, LLC, et al. 2/03/21 – Final Approval 

No. 19-CH-11117 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

The Court granted final approval of more than half a million dollar settlement on behalf of employees whose rights were 

violated under the Biometric Information Privacy Act (“BIPA”). 

Collier, et al. v. Pete’s Fresh Market, et al. 12/03/20 – Final Approval 

No. 19-CH-05125 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Stephan Zouras, LLP secured over $4.2 million for thousands of employees whose rights were violated under the 

Biometric Information Privacy Act (“BIPA”). 

Bryant, et al. v. Loews Chicago Hotel, Inc. et al. 10/30/20 – Final Approval 

No. 19-cv-03195 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP settled for approximately $1 million on behalf of employees whose rights were violated under the 

Biometric Information Privacy Act (“BIPA”). 

Bigger, et al. v. Facebook, Inc. 10/22/20 – Final Approval 

No. 17-cv-7753 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP secured over $1.6 million on behalf of Client Solutions Managers (“CSMs”) who were misclassified 

as exempt from overtime requirements and deprived of overtime wages in violation of FLSA and the Illinois Minimum 

Wage Law (“IMWL”). 

Johns, et al. v. Club Fitness of Alton, LLC 10/13/2020 – Final Approval 

No. 18-L-000080 (Circuit Court of Madison County, Law Division, State of Illinois) 

The Court granted final approval of more than half a million dollar settlement on behalf of employees whose rights 

were violated under the Biometric Information Privacy Act (“BIPA”). 

Bryski, et al. v. Nemera Buffalo Grove, LLC, et al. 10/05/20 – Final Approval 

No. 18-CH-07264 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Stephan Zouras, LLP secured nearly half a million dollar settlement on behalf of employees whose rights were violated 

under the Biometric Information Privacy Act (“BIPA”). 

Thomas, et al. v. Kik Custom Products, Inc. 9/30/20 – Final Approval 

No. 19-CH-02471 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

As co-counsel, Stephan Zouras, LLP settled for approximately $1 million on behalf of employees based on alleged 

violations of the Biometric Information Privacy Act (“BIPA”).

Gauzza, et al. v. Prospect Medical Holdings, Inc., et al. 9/15/20 – Final Approval 

No. 20-cv-03599 (United States District Court for the Eastern District of Pennsylvania) 

As lead counsel, Stephan Zouras, LLP, secured $1.9 million in unpaid overtime wages on behalf of hundreds of full-time 

hourly employees whose hands-on patient care responsibilities resulted in interrupted meal breaks, which were not 

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compensated for. 

Bradford, et al. v. Farmington Foods, Inc. 8/17/20 – Final Approval 

No. 19-CH-12888 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

The Court granted final approval in a six-figure class settlement on behalf of hundreds of employees whose rights were 

violated under the Biometric Information Privacy Act (“BIPA”). 

Trottier, et al. v. Summit Staffing 8/04/20 – Final Approval 

No. 19-CH-02731 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Stephan Zouras, LLP settled for approximately $1 million on behalf of thousands of employees based on alleged 

violations of the Biometric Information Privacy Act (“BIPA”).

Jackson, et al. v. A. Finkl & Sons, Co., et al. 7/21/20 – Final Approval 

No. 2018-CH-07424 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Final approval was granted in a six-figure class settlement on behalf of employees whose rights were violated under the 

Biometric Information Privacy Act (“BIPA”). 

Thome, et al. v. Flexicorps. Inc. 7/02/20 – Final Approval 

No. 18-CH-01751 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

As co-counsel, Stephan Zouras, LLP settled for approximately $1 million on behalf of employees based on alleged 

violations of the Biometric Information Privacy Act (“BIPA”).

Goings, et al. v. Applied Acoustics, et al. 6/02/20 – Final Approval 

No. 17-CH-14954 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Final approval was granted in a six-figure class settlement on behalf of employees whose rights were violated under the 

Biometric Information Privacy Act (“BIPA”). 

Jones, et al. v. Santa Rosa Consulting, Inc. 5/26/20 – Final Approval 

No. 18-cv-11005 (United States District Court for the Southern District of New York) 

The Court granted approval of a six-figure settlement on behalf of consultants misclassified as independent contractors 

who were not paid overtime premium compensation as required by the FLSA and New York Law. 

Jones, et al. v. Encore Health Resources, LLC, et al. 2/19/20 – Final Approval 

No. 19-cv-03298 (United States District Court for the Southern District of Texas) 

The Court granted approval of a six-figure settlement on behalf of credentialed trainers who worked in excess of 40 

hours per week but were not compensated overtime premium rate, as required by the FLSA. 

Potoski, et al. v. Wyoming Valley Health Care System, et al. 1/14/20 – Final Approval 

No. 11-cv-00582 (United States District Court for the Middle District of Pennsylvania) 

As lead co-counsel, Stephan Zouras, LLP helped achieve a six-figure class settlement on behalf of hospital employees 

who were required to perform uncompensated work “off-the-clock” during meal breaks. 

Stewart, et al. v. First Transit, Inc. 12/30/19 – Final Approval 

No. 18-cv-03768 (United States District Court for the Eastern District of Pennsylvania)

Final approval was granted in a six-figure class settlement achieved by Stephan Zouras, LLP for hundreds of paratransit 

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drivers who were not paid for work during “scheduled gap periods.” 

Jordan, et al. v. Meridian Bank, et al. 12/19/19 – Final Approval 

No. 17-cv-05251 (United States District Court for the Eastern District of Pennsylvania) 

Stephan Zouras, LLP served as co-counsel and achieved a nearly $1 million class settlement on behalf of thousands of 

misclassified loan officers who were not paid minimum or overtime wages as required by federal and state law. 

George, et al. v. Schulte Hospitality Group, Inc. 12/16/19 – Final Approval 

No. 18-CH-04413 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

The Court granted final approval of an almost $1 million settlement on behalf of approximately 900 employees whose 

rights were violated under the Biometric Information Privacy Act (“BIPA”). 

Edmond, et al. v. DPI Specialty Foods, Inc. 11/18/19 – Final Approval 

No. 18-CH-09573 (Circuit Court of Cook County, Chancery Division, State of Illinois)

The Court granted final approval of a nearly $500,000 settlement on behalf of hundreds of employees whose rights were 

violated under the Biometric Information Privacy Act (“BIPA”). 

Watts, et al. v. Chicago Lakeshore Hospital 11/13/20 – Final Approval

No. 17-CH-12756 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Final approval for class settlement in the amount of approximately $900,000 was granted and awarded to employees 

whose rights were violated under the Biometric Information Privacy Act (“BIPA”).

Bey v. Walker HealthCare, et al. & Pierce, et al. v. Encore Health Resources, et al. 9/19/2019 – Final Approval 

No’s. 19-cv-00060, 18-cv-04736 (United States District Court for the Southern District of Texas) 

Stephan Zouras, LLP achieved a nearly $2.4 million settlement on behalf of employees identified as “At-The-Elbow” 

(“ATE”) consultants who worked in excess of 40 hours per week and were denied proper overtime compensation. 

Kuck v. Planet Home Lending, LLC, et al. 9/13/19 – Final Approval 

No. 17-cv-04769 (United States District Court for the Eastern District of New York) 

Stephan Zouras, LLP helped achieve a six-figure class settlement on behalf of Retail Retention Mortgage Loan Officers 

who were required to perform work off-the-clock and were denied overtime wages. 

Dixon v. The Washington & Jane Smith Home, et al. 8/20/19 – Final Approval 

No. 17-cv-08033 (United States District Court for the Northern District of Illinois) 

Final approval in a class wide settlement was granted and awarded in the amount of $1,356,000 to approximately 1,300 

employees based on alleged violations of the Biometric Information Privacy Act (“BIPA”). 

Jones v. Chicago Bridge & Iron Company, et al. 8/06/19 – Final Approval 

No. 17-cv-00424 (United States District Court for the Western District of North Carolina) 

As co-lead counsel, Stephan Zouras, LLP helped achieve a six-figure class settlement on behalf of employees who worked 

for defendants under a 9/80 pay plan (A-B Schedule) and were not paid an overtime premium for hours worked in 

excess of forty in a workweek. 

Sharrieff v. Raymond Management Company, et al. 8/01/2019 – Final Approval 

No. 18-CH-01496 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

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A six-figure class settlement was granted and awarded to hundreds of employees based on alleged violations of the 

Biometric Information Privacy Act (“BIPA”). 

Ostrander v. Customer Engineering Services, LLC 3/25/19 – Final Judgment 

No. 15-cv-01476 (United States District Court of Colorado) 

Final approval of a six-figure class settlement was granted on behalf of technical service representatives who were 

misclassified under the federal law and were deprived of earned overtime wages. 

Davis v. Vanguard Home Care, LLC, et al. 3/22/19 – Final Approval 

No. 16-cv-07277 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP achieved a six-figure class settlement on behalf of a group of Home Health Clinicians who were 

misclassified as exempt under federal and state wage laws. 

Goh v. NCR Corporation 2/25/19 – Final Approval 

No. 01-15-0004-0067 (AAA Arbitration) 

In granting class certification and approval of a settlement in excess of six figures for over three-thousand class members 

employed by NCR who were subjected to improper background checks, the Arbitrator found that the attorneys of 

Stephan Zouras “rendered exemplary services for [their] clients and acted with great care, diligence, and 

professionalism.” 

Moseman v. U.S. Bank National Association 1/07/19 – Final Approval 

No. 17-cv-00481 (United States District Court for the Western District of North Carolina) 

As lead counsel, Stephan Zouras, LLP achieved a class wide settlement on behalf of individuals employed as AML/BSA 

Preliminary Investigators who worked in excess of 40 hours per week and were not paid proper overtime compensation. 

Ivy v. Adventist Midwest Health 11/14/18 – Final Approval 

No. 16-cv-7606 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP achieved a six-figure class settlement on behalf of Home Health Clinicians who worked in excess 

of 40 hours per week and were not paid overtime. 

Bhattacharya v. Capgemini, et al. 11/13/18 – Final Approval 

No. 16-cv-07950 (United States District Court for the Northern District of Illinois) 

Final approval for class settlement in the amount of $990,000.00 was granted and awarded to approximately 900 Indian 

national participants of Capgemini’s Group Health Plan based on alleged violations of the Employee Retirement Income 

Security Act (“ERISA”). 

Carver v. Presence Health Network, et al. 7/10/18 – Final Approval 

No. 15-cv-02905 (United States District Court for the Northern District of Illinois)

Stephan Zouras, LLP helped achieve final approval of a seven-figure class settlement on behalf of participants and 

beneficiaries of benefit plans sponsored by Presence Health based on alleged violations of the Employee Retirement 

Income Security Act (“ERISA”). 

Lukas v. Advocate Health Care, et al. 6/27/18 – Final Approval 

No. 14-cv-01873 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP helped achieve final approval of a seven-figure class settlement on behalf of thousands of 

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participants and beneficiaries to Advocate Health Care Network’s Pension Plan based on alleged violations of the 

Employee Retirement Income Security Act (“ERISA”). 

Brown v. Health Resource Solutions, Inc. 4/20/18 – Final Approval 

No. 16-cv-10667 (United States District Court for the Northern District of Illinois) 

The Court granted final approval of class settlement for $900,000.00 in unpaid overtime wages on behalf of Home Health 

Clinicians who were misclassified as exempt under federal and state wage laws.

Eggleston v. USCC Services, LLC. 2/16/18 – Final Approval 

No. 16-cv-06775 (United States District Court for the Northern District of Illinois) 

As co-lead counsel, Stephan Zouras, LLP helped obtain final approval of a $1,250,000 class settlement for unpaid 

overtime wages on behalf of misclassified Sales Managers. 

Caison v. Sogeti USA, LLC, et al. 2/12/18 – Final Approval 

No. 17-cv-2786 (United States District Court for the Northern District of Illinois) 

As lead counsel, Stephan Zouras, LLP achieved a class wide settlement on behalf of hundreds of Business Analysts who 

worked in excess of 40 hours per week and were not paid proper overtime compensation. 

Kaminski v. Bank of America, N.A. 2/15/18 – Final Approval 

No. 16-cv-10844 (United States District Court for the Northern District of Illinois) 

Final approval for class settlement in the amount of $850,000 in unpaid wages was granted and awarded to a class of 

approximately 100 employees working as Senior Specialist-Securities and Operation Market Professionals.

Byrne v. Centegra Health System 1/29/18 – Final Approval 

No. 17-cv-00018 (United States District Court for the Northern District of Illinois) 

The Court granted final approval of class settlement for $425,000 in unpaid overtime wages on behalf of registered 

nurses, physical therapists, occupational therapists, speech therapists and other similarly-designated skilled care 

positions who were misclassified as exempt under federal and state wage laws.

Donoghue v. Verizon Communications, Inc. 11/16/17 – Final Approval 

No. 16-cv-4742 (United States District Court for the Eastern District of Pennsylvania) 

The Court granted final approval of class settlement for $800,000 in unpaid overtime wages on behalf of wireline workers 

who were hired to fill in for Verizon employees during a strike. Despite regularly working 65 hours per week, these 

employees were classified as exempt and denied overtime wages. 

Tompkins v. Farmers Insurance Exchange 9/27/17 – Final Approval 

No. 14-cv-3737 (United States District Court for the Eastern District of Pennsylvania) 

The Court granted final approval of a $775,000.00 class settlement on behalf misclassified loan officers seeking unpaid 

overtime wages. 

In re Sears Holdings Corporation Stockholder and Derivative Litigation 5/9/17 – Final Approval 

No. 11081-VCL (Court of Chancery of the State of Delaware) 

Stephan Zouras, LLP represented the Named Plaintiff in a $40 million settlement in connection with a 2015 sale by Sears 

of 235 properties to Seritage Growth Properties. 

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Oaks v. Sears 4/12/17 – Final Approval 

No. 1:15-cv-11318 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP settled on behalf of thousands of consumers who own or once owned Sears Kenmore grills in a 

product defect class action. 

Hauser v. Alexian Brothers Home Health 4/06/17 – Final Approval

No. 15-cv-6462 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP settled for $1 million on behalf of home health care clinicians who were misclassified as “exempt” 

and deprived of earned overtime wages. 

Leiner v. Johnson & Johnson 1/31/17 – Final Approval 

No. 15-cv-5876 (United States District Court for the Northern District of Illinois) 

The Court granted final approval of a $5 million settlement for consumers nationwide in a consumer fraud class 

action. Stephan Zouras, LLP represented consumers who were deceived into paying premium prices for Johnson & 

Johnson baby bedtime products which falsely claimed to help babies sleep better. 

Reed v. Friendly’s Ice Cream, LLC, et al. 1/31/17 – Final Approval 

No. 15-cv-00298 (United States District Court for the Middle District of Pennsylvania) 

Stephan Zouras, LLP served as co-counsel and helped obtain final approval of a $3,500,000 class settlement on behalf 

of nationwide Servers who were not compensated for off-the-clock worked performed during unpaid meal breaks and 

after their scheduled shifts. 

McPhearson v. 33 Management 11/3/16 – Final Approval 

No. 15-ch-17302 (Circuit Court of Cook County, Chancery Divisions, State of Illinois) 

The Court granted final approval of class settlement on behalf of tenants of a Chicago apartment building where the 

landlords violated the City of Chicago Residential Landlord and Tenant Ordinance by collecting and holding tenant 

security deposits without paying interest earned. 

Cook v. Bank of America 8/2/16 – Final Approval 

No. 15-cv-07718 (United States District Court for the Northern District of Illinois) 

The Court granted final approval of $3,250,000 settlement for an Illinois Class and FLSA Collective on behalf of 

individuals who worked as Treasury Services Advisors and who were misclassified as exempt from earned overtime 

wages.

Altnor v. Preferred Freezer Services, Inc. 7/18/16 – Final Approval 

No. 14-cv-7042 (United States District Court for the Eastern District of Pennsylvania) 

The firm’s attorneys served as lead counsel in this lawsuit seeking recovery of wages for unpaid meal break work for a 

class of 80 cold storage warehouse workers. 

Lukas v. Advocate Health Care 6/29/16 – Final Approval 

No. 14-cv-2740 (United States District Court for the Northern District of Illinois) 

The Court granted final approval of a $4,750,000 settlement for a federal FLSA and Illinois Minimum Wage Law collective 

class of home health care clinicians who were wrongly classified as “exempt” from federal and state overtime laws.

Kurgan v. Chiro One Wellness Centers LLC 4/27/16 – Final Approval

No. 10-cv-1899 (United States District Court for the Northern District of Illinois) 

The Court granted Plaintiffs’ motion for Section 216(b) certification of Plaintiffs’ FLSA claim, granted Rule 23 certification 

of Plaintiffs’ claims under the Illinois Minimum Wage Law and appointed Stephan Zouras, LLP as counsel for a class of 

chiropractic technicians and assistants. 

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Heba v. Comcast 4/6/16 – Final Approval 

No. 12-471 (First Judicial District of Pennsylvania Court of Common Pleas of Philadelphia) 

The Court granted class certification to Customer Account Executives who worked at Comcast’s Pennsylvania call centers 

and were required to work 15 minutes a day before their scheduled start time without pay. As lead counsel, Stephan 

Zouras, LLP achieved a favorable resolution for over 6,000 class members. 

Johnson v. Casey’s General Stores, Inc. 3/3/16 – Final Approval 

No. 15-cv-3086 (United States District Court for the Western District of Missouri) 

The Court granted final approval on behalf of a certified class of employees of Casey’s General Stores, Inc. to redress 

violations of the Fair Credit Reporting Act (FCRA). 

Fields v. Bancsource, Inc. 2/3/16 – Final Approval 

No. 14-cv-7202 (United States District Court for the Northern District of Illinois) 

The Court entered an order granted Plaintiffs’ motion for Section 216(b) certification of a class of field engineers who 

were deprived of overtime for hours worked in excess of 40 in given workweeks. 

Elder, et al. v. Comcast Corporation 1/11/16 – Final Approval

No. 12-cv-1157 (United States District Court for the Northern District of Illinois) 

The Court granted Plaintiffs' motion for conditional certification and appointed Stephan Zouras, LLP as counsel for a 

class of cable technicians who allege they were deprived of overtime wages in violation of federal law. 

Posada, et al. v. Continental Home Loans, Inc. 1/13/16 - Final Approval 

15-cv-4203 (United States District Court for the Eastern District of New York) 

Stephan Zouras, LLP was appointed class counsel and achieved a substantial settlement on behalf of a class of loan 

officers deprived of minimum and overtime wages. 

Struett v. Susquehanna Bank 10/27/15 – Final Approval 

No. 15-cv-176 (United States District Court for the Eastern District of Pennsylvania) 

The firm’s attorneys served as co-lead counsel in this lawsuit which recovered $300,000 in unpaid overtime wages for 

31 misclassified loan officers. 

Faust, et al. v. Comcast Corporation 10/11/15 - Final Approval 

No. 10-cv-2336 (United States District Court for the Northern District of Maryland) 

The Court granted Plaintiffs' motion for conditional certification and appointed Stephan Zouras, LLP lead counsel for a 

class of call center employees. 

Butler, et al. v. Direct Sat 9/3/15 - Final Approval 

No. 10-cv-08747 DKC (United States District Court for the District of Maryland) 

Stephan Zouras, LLP reached favorable resolution on behalf of a finally-certified collective class of technicians working 

in DirectSat’s Maryland warehouses who were not paid overtime.

Sosnicki v. Continental Home Loans, Inc. 7/30/15 - Final Approval 

No. 12-cv-1130 (United States District Court for the Eastern District of New York) 

As lead class counsel, Stephan Zouras, LLP achieved a six-figure settlement on behalf of a collective class of loan officers 

who were deprived of minimum wages and overtime in violation of federal and state law. 

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Bordell v. Geisinger Medical Center 4/8/15 – Final Approval 

No. 12-cv-1688 (Northumberland Court of Common Pleas) 

The firm’s attorneys served as lead counsel in this lawsuit which challenged Defendant’s workweek averaging practices 

and recovered $499,000 in unpaid overtime wages for hospital workers. 

Harvey, et al. v. AB Electrolux, et al. 3/23/15 – Final Approval

No. 11-cv-3036 (United States District Court for the Northern District of Iowa) 

As lead counsel, Stephan Zouras, LLP achieved a six-figure settlement amount on behalf of hundreds of production 

workers seeking unpaid earned wages. 

Price v. NCR Corporation 3/18/15 – Final Approval 

No. 51-610-908-12 (AAA Arbitration) 

As lead class counsel, Stephan Zouras, LLP achieved a seven figure, arbitrator approved settlement on behalf of 

thousands of Customer Engineers nationwide who were deprived overtime wages in violation of federal law.

Frebes, et al. v. Mask Restaurants, LLC 1/15/15 – Final Approval 

No. 13-cv-3473 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP was appointed class counsel and achieved a substantial settlement on behalf of hundreds of servers, 

bartenders and bussers forced to participate in an illegal “tip pool.” 

Jones v. Judge Technical Services Inc. 12/15/14 – Final Approval 

No. 11-cv-6910 (United States District Court for the Eastern District of Pennsylvania) 

As lead class counsel, Stephan Zouras, LLP prevailed on summary judgment and subsequently achieved a seven-figure 

settlement on behalf of IT workers who were designated under the “Professional Day” or “Professional Week” 

compensation plan, misclassified as exempt from the FLSA and denied overtime pay. 

Howard, et al. v. Securitas Security Services USA, Inc. 5/7/14 – Final Approval

No. 08-cv-2746 (United States District Court for the Northern District of Illinois) 

and, 

Hawkins v. Securitas Security Services USA, Inc. 

No. 09-cv-3633 (United States District Court for the Northern District of Illinois) 

For settlement purposes, the Court certified a class of approximately ten thousand security guards seeking damages for 

unpaid wages and overtime under the FLSA and Illinois Minimum Wage Law. 

Thomas v. Matrix Corporation Services 2/12/14 – Final Approval

No. 10-cv-5093 (United States District Court for the Northern District of Illinois) 

As lead counsel, Stephan Zouras, LLP achieved a six-figure settlement on behalf of a class of hundreds of technicians 

who allege they were deprived of overtime wages in violation of federal law. 

Ingram v. World Security Bureau 12/17/13 – Final Approval

No. 11-cv-6566 (United States District Court for the Northern District of Illinois) 

Stephan Zouras secured a class settlement on behalf of several hundred security officers deprived of minimum wages 

and overtime in violation of federal and state law. 

Sexton v. Franklin First Financial 9/30/13 – Final Approval 

No. 08-cv-04950 (United States District Court for the Eastern District of New York) 

Stephan Zouras, LLP achieved a settlement on behalf of a class of approximately 150 loan officers deprived of minimum 

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wages and overtime in violation of the FLSA. 

Outlaw v. Secure Health, L.P. 9/24/13 – Final Approval 

No. 11-cv-602 (United States District Court for the Eastern District of Pennsylvania) 

The firm’s attorneys served as lead counsel in this lawsuit seeking recovery of wages for unpaid pre-shift, meal break 

and uniform maintenance work for a class of 35 nursing home workers. 

Robinson v. RCN Telecom Services, Inc. 8/5/13 – Final Approval 

No. 10-cv-6841 (United States District Court for the Eastern District of Pennsylvania) 

The firm’s attorneys served as co-lead counsel in this lawsuit which recovered $375,000 in unpaid overtime wages for 

misclassified cable television installers. 

 

Holland v. Securitas Security Services USA, Inc. 7/26/13- Final Approval

No. BC 394708 (Superior Court of California, County of Los Angeles) 

As class counsel, Stephan Zouras, LLP achieved a six figure settlement on behalf of thousands of security officers who 

allege they were deprived of overtime wages in violation of federal law. 

Jankuski v. Heath Consultants, Inc. 7/2/13 - Final Approval

No. 12-cv-04549 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP was appointed lead counsel and achieved a settlement on behalf of gas management technicians 

deprived of minimum wages and overtime in violation of the FLSA. 

Ord v. First National Bank of Pennsylvania 6/21/13 – Final Approval 

No. 12-cv-766 (United States District Court for the Western District of Pennsylvania) 

The firm’s attorneys served as co-lead counsel in this consumer fraud lawsuit which recovered $3,000,000 for consumers 

who had been made to pay improper overdraft fees. 

Holley v. Erickson Living Management, LLC 6/13/13 – Final Approval 

No. 11-cv-2444 (United States District Court for the Eastern District of Pennsylvania) 

The firm’s attorneys served as lead counsel in this lawsuit seeking recovery of wages for unpaid pre-shift and meal break 

work for a class of 63 nursing home workers. 

Hansen, et al. v. Per Mar Security Services 5/15/13 - Final Approval

No. 09-cv-459 (United States District Court for the Southern District of Iowa) 

Stephan Zouras, LLP was appointed class counsel and secured a settlement for hundreds of security guards deprived of 

minimum wages and overtime in violation of federal and state law. 

Pomphrett v. American Home Bank 3/14/13 – Final Approval

No. 12-cv-2511 (United States District Court for the Eastern District of Pennsylvania) 

The firm’s attorneys served as co-lead counsel in this lawsuit which recovered $2,400,000 in unpaid overtime wages for 

misclassified loan officers. 

Murphy v. Rayan Brothers, et al. 2/22/13 - Final Approval

No. 11 CH 03949 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Stephan Zouras, LLP achieved class wide recovery on behalf of a class of tenants for violations of the Chicago Residential 

Landlord and Tenant Ordinance (RLTO). 

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Glatts v. Crozer-Keystone Health System 2/6/13 – Final Approval 

No. 0904-1314 (Philadelphia Court of Common Pleas) 

The firm’s attorneys served as co-lead counsel in this lawsuit which challenged Defendant’s workweek averaging 

practices and recovered $1,200,000 in unpaid overtime wages for hospital workers. 

Chambers v. Front Range Environmental, LLC 1/23/13 - Final Approval 

No. 12-cv-891 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP was appointed as class counsel and resolved this action on behalf of a class of maintenance workers.

Piehl v. Baytree National Bank 1/3/13 - Final Approval 

No. 12-cv-1364 (United States District Court for the Northern District of Illinois)

Stephan Zouras, LLP was appointed class counsel and resolved this action on behalf of a class of Indiana loan officers 

who were paid on a commission-only basis and deprived of earned minimum wage and overtime in violation of the 

FLSA. 

Searson v. Concord Mortgage Corporation 11/19/12 - Final Approval 

No. 07-cv-3909 (United States District Court for the Eastern District of New York)

Stephan Zouras, LLP achieved a settlement on behalf of a class of 80 loan officers deprived of minimum wages and 

overtime in violation of the FLSA. 

Ellenbecker, et al. v. North Star Cable Construction, Inc., et al. 11/14/12 - Final Approval 

No. 09-cv-7293 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP obtained Rule 23 certification, were appointed lead counsel, and achieved a significant monetary 

resolution for a class of several hundred cable technicians seeking unpaid overtime wages and the recovery of improper 

deductions from their pay. 

Williams, et al. v. Securitas Security Services USA, Inc. 11/8/12 - Final Approval 

No. 10-cv-7181 (United States District Court for the Eastern District of Pennsylvania) 

As lead class counsel, Stephan Zouras, LLP achieved a settlement on behalf of a class of Pennsylvania security guards 

who were not paid for all time spent in training and orientation. 

Lacy, et al. v. The University of Chicago Medical Center 11/6/12 – Final Approval

No. 11-cv-5268 (United States District Court for the Northern District of Illinois) 

As lead class counsel, Stephan Zouras, LLP achieved a FLSA settlement for a collective class of hospital respiratory 

therapists.

Molyneux, et al. v. Securitas Security Services USA, Inc. 11/5/12 - Final Approval 

No. 10-cv-588 (United States District Court for the Southern District of Iowa) 

As lead class counsel, Stephan Zouras achieved a settlement on behalf of a class of Iowa and Wisconsin security guards 

who were not paid for all time spent in training and orientation. 

Davis v. TPI Iowa, LLC 9/6/12 - Final Approval 

No. 11-cv-233 (United States District Court for the Southern District of Iowa) 

As class counsel, Stephan Zouras, LLP achieved a settlement on behalf of a collective class of production employees. 

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Kernats, et al. v. Comcast Corporation 5/28/12 - Final Approval 

No. 09-cv-3368 (United States District Court for the Northern District of Illinois)

As lead class counsel, Stephan Zouras, LLP achieved a seven-figure settlement on behalf of over 7,500 Customer Account 

Representatives (CAEs) for unpaid wages in a Rule 23 class action brought under Illinois wage law. 

Garcia, et al. v. Loffredo Fresh Produce Co., Inc. 5/24/12 - Final Approval 

No. 11-cv-249 (United States District Court for the Southern District of Iowa)

As class counsel, Stephan Zouras, LLP achieved a settlement on behalf of a collective class of produce processing 

employees. 

Larsen, et al. v. Clearchoice Mobility, Inc., et al. 3/21/12 - Final Approval

No. 11-cv-1701 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP achieved an FLSA settlement on behalf of a collective class of retail sales consultants. 

Etter v. Trinity Structural Towers 1/26/12 - Final Approval

No. 11-cv-249 (United States District Court for the Southern District of Iowa) 

As class counsel, Stephan Zouras, LLP achieved a settlement on behalf of a collective class of production employees. 

Petersen, et al v. Marsh USA, Inc. et al. 9/21/11 - Final Approval

No. 10-cv-1506 (United States District Court for the Northern District of Illinois) 

Stephan Zouras, LLP achieved a six-figure settlement on behalf of over 30 analysts who claimed they were misclassified 

under the FLSA. 

Thompson v. World Alliance Financial Corp. 8/5/11 - Final Approval

No. 08-cv-4951 (United States District Court for the Eastern District of New York) 

Stephan Zouras, LLP were appointed lead counsel and achieved a settlement on behalf of a class of over one hundred 

loan officers deprived of minimum wages and overtime in violation of federal and state law. 

Vaughan v. Mortgage Source LLC, et al. 6/16/11 - Final Approval

No. 08-cv-4737 (United States District Court for the Eastern District of New York) 

Stephan Zouras, LLP were appointed lead counsel and achieved a settlement on behalf of a class of loan officers deprived 

of minimum wages and overtime in violation of federal and state law. 

Harris, et al. v. Cheddar's Casual Cafe, Inc. 6/1/11 - Final Approval

No. 51 460 00557 10 (AAA Arbitration) 

Stephan Zouras served as lead counsel in six-figure class settlement on behalf of over 100 restaurant workers deprived 

of minimum wages and overtime. 

Turner v. Mercy Health System 4/20/11 – Final Approval 

No. 0801-3670 (Philadelphia Court of Common Pleas) 

The firm’s attorneys served as co-lead counsel in this lawsuit which challenged Defendant’s workweek averaging 

practices and, in a case of first impression, recovered $2,750,000 in unpaid overtime wages for hospital workers. 

Brown et al. v. Vision Works, et al. 3/4/11 - Final Approval

No. 10-cv-01130 (United States District Court for the Northern District of Illinois) 

As lead class counsel, Stephan Zouras, LLP achieved a settlement on behalf of retail store managers improperly classified 

as exempt from overtime.

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Havard v. Osceola Foods, Inc., et al. 2/28/11 - Final Approval

No. LA CV 0111290 (Iowa District for Clarke County, Iowa) 

As lead class counsel, Stephan Zouras, LLP achieved a class settlement on behalf of meat processing plant employees 

who were not properly paid for donning and doffing activities performed before their shifts, during meal breaks and 

after their shifts. 

Lagunas v. Cargill Meat Solutions Corp. 1/27/11 - Final Approval

No. 10-cv-00220 (United States District Court for the Southern District of Iowa) 

Stephan Zouras, LLP served as co-lead counsel in class settlement on behalf of meat processing plant employees who 

were not properly paid for donning and doffing activities performed before their shifts, during meal breaks and after 

their shifts.

Anderson v. JCG Industries, Inc. 9/2/10 - Final Approval

No. 09-cv-1733 (United States District Court for the Northern District of Illinois) 

As lead class counsel, Stephan Zouras, LLP achieved a six-figure settlement on behalf of meat processing plant 

employees who were not properly paid for time worked before their shifts, during meal breaks and after their shifts. 

Cedeno, et al. v. Home Mortgage Desk, Corp., et al. 6/15/10 - Final Approval

No. 08-cv-1168 (United States District Court for the Eastern District of New York) 

Stephan Zouras, LLP along with co-counsel was appointed lead counsel and achieved a six-figure settlement on behalf 

of a Section 216(b) collective class of loan officers deprived of overtime wages. 

Perkins, et al. v. Specialty Construction Brands, Inc. 11/15/09 - Final Approval

No. 09-cv-1678 (United States District Court for the Northern District of Illinois) 

As lead class counsel, Stephan Zouras, LLP achieved a six-figure wage and hour settlement on behalf of a collective class 

of plant employees for claims of unpaid overtime, including time worked before the start of their shifts, during breaks 

and after the end of their shifts. 

Wineland, et al. v. Casey's General Stores, Inc. 10/22/09 - Final Approval

No. 08-cv-00020 (United States District Court for the Southern District of Iowa) 

Stephan Zouras, LLP along with co-counsel was appointed lead counsel and achieved a seven-figure settlement on 

behalf of a Section 216(b) collective class and Rule 23 class of over 10,000 cooks and cashiers for unpaid wages, 

including time worked before and after their scheduled shifts and while off-the-clock.

Jones, et al. v. Casey's General Stores, Inc. 10/22/09 - Final Approval

No. 07-cv-400 (United States District Court for the Southern District of Iowa) 

Stephan Zouras, LLP along with co-counsel was appointed lead counsel and achieved a seven-figure settlement on 

behalf of a Section 2 l 6(b) collective class and Rule 23 class of assistant store managers for unpaid wages, including 

time worked before and after their scheduled shifts and while off-the-clock. 

Stuart, et al. v. College Park, et al. 12/11/07 - Final Approval

No. 05 CH 09699 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

The firm's partners served as co-lead counsel in this case brought on behalf of a class of tenants who were seeking the 

refund of their security deposits. As a result of their efforts, Mr. Stephan and Mr. Zouras helped achieve a six-figure 

settlement on behalf of a class of over 100 tenants. 

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Huebner et al. v. Graham C Stores 11/15/07 - Final Approval

No. 06 CH 09695 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

Ryan Stephan of Stephan Zouras, LLP served as co-lead counsel in this wage and hour case involving claims for unpaid 

wages by a class of gas station employees. Mr. Stephan helped achieve a six-figure settlement for over 100 employees. 

Perez, et al. v. RadioShack Corporation 9/14/07 - Final Approval 

No. 02-cv-7884 (United States District Court for Northern District of Illinois) 

The firm's partners served as co-lead counsel in this nationwide Fair Labor Standards Act ("FLSA") overtime action 

brought on behalf of 4,000 retail store managers. Plaintiffs claimed they were improperly classified as exempt from the 

FLSA and owed overtime compensation for all hours worked in excess of 40 each week. In a case of first impression, the 

Court granted summary judgment in favor of a sub-class of Plaintiffs who did not "regularly and customarily" supervise 

at least 80 hours of subordinate time per week at least 80% of the time as required by the executive exemption of the 

FLSA. The reported decision is Perez v. RadioShack Corp., 386 F. Supp. 979 (N.D. Ill. 2005). As a result of the efforts of 

Plaintiffs' counsel, Plaintiffs obtained a nearly $9 million settlement on the eve of trial. 

Reinsmith, et al. v. Castlepoint Mortgage 4/3/07 - Final Approval

No. 05-cv-01168 (United States District Court, Eastern District of Massachusetts) 

The firm's partners served as co-lead counsel in this action brought on behalf of a collective class of loan officers seeking 

to recover unpaid overtime. Mr. Stephan and Mr. Zouras helped achieve a seven-figure settlement on behalf of over 

100 loan officers in this case. 

Kutcher, et al. v. B&A Associates 11/20/06 - Final Approval

No. 03 CH 07610 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

The firm's partners served as co-lead counsel in this case brought on behalf of a class of tenants who were seeking 

damages based on alleged security deposit violations. As a result of their efforts, Mr. Stephan and Mr. Zouras helped 

achieve a six-figure settlement on behalf of a class of over 100 tenants. 

Ciesla, et al. v. Lucent Technologies, Inc. 7/31/06 - Final Approval

No. 05-cv-1641 (United States District Court for the Northern District of Illinois) 

The firm's partners served as co-lead counsel in this breach of contract class action against a high-tech communications 

company. Mr. Stephan and Mr. Zouras helped obtain a seven-figure settlement on behalf of the class. 

Casale, et al. v. Provident Bank 7/25/05 - Final Approval

No. 04-cv-2009 (United States District Court for the District of New Jersey) 

The firm's partners served as co-lead counsel in this case brought on behalf of a collective class of over 100 loan officers 

who were seeking damages based on wage and hour violations of the FLSA. As a result of their efforts, Mr. Stephan and 

Mr. Zouras helped achieve a seven-figure settlement on behalf of the Plaintiffs. 

Corbin, et al. v. Barry Realty 3/22/05 - Final Approval

No. 02 CH 16003 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

The firm's partners served as co-lead counsel in this case brought on behalf of a class of tenants who were seeking the 

refund and interest on their security deposits as called for by the Chicago Residential Landlord Tenant Ordinance. As a 

result of their efforts, Mr. Stephan and Mr. Zouras helped achieve a six-figure settlement on behalf of a class of over 

100 tenants. 

Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 26 of 37 PageID #:4119
BIOMETRIC INFORMATION PRIVACY CLASS ACTION LAWSUITS 

Our firm is at the forefront of BIPA litigation to protect the biometric data and privacy of employees and 

consumers. We have brought numerous class action lawsuits against employers and other retail businesses 

who have collected biometric data without consent and without instituting the proper safeguards including; 

x Ala, et al v. U.S. Acrylic, LLC 

No. 22-CH-0000069 (Circuit Court of Lake County, Chancery Division, State of Illinois) 

x Alderman, et al. v. The Kroger Co. 

No. 2021-L-21 (Circuit Court of Williamson County, Law Division, State of Illinois) 

x Alquero, et al. v. Grand Victoria Riverboat Casino, et al. 

No. 19-CH-09603 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Andere, et al. v. Amita Health Adventist Medical Center Bolingbrook 

No. 2021-L-000893 (Circuit Court of Will County, Law Division, State of Illinois) 

x Anthony, et al v. Abbott Laboratories, et al. 

No. 21-CH-00000385 (Circuit Court of Lake County, Chancery Division, State of Illinois) 

x Anthony, et al. v. Townplace Suites, et al. 

No. 2021-CH-05389 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Anthony, et al. v. Walmart, Inc. 

No. 2021-CH-05385 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Arnold, et al. v. Roundy’s Supermarkets, Inc., et al. 

No. 20-CH-05622 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Arroyo, et al. v. OTO Development, LLC 

No. 20-CH-07170 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Ayala, et al. v. American Louver Company 

No. 19-CH-04163 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Biloche, et al. v. Glenview Terrace Property, LLC 

No. 21-CH-00529 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Blunt, et al. v. G2K Logistics, LLC et al. 

No. 2022-CH-01637 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Boyd, et al. v. Lazer Spot, Inc. 

No. 19-CH-12511 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Brammer, et al. v. Ava Inc., et al. 

No. 19-CH-07379 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Bray, et al. v. Lathem Time Co., 

No. 2019L8 (Circuit Court of Montgomery County, State of Illinois) 

x Broadnax, et al. v. Crescent Cardboard Company 

No. 2021-CH-04581 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Broadnax, et al. v. Nielsen & Bainbridge, LLC 

No. 2021-CH-04580 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Brown, et al. v. Weathertech 

No. 19-CH-00503 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Bryant, et al v. Norwood Life Society, et al. 

Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 27 of 37 PageID #:4120
No. 19-CH-10984 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Buford, et al. v. GDI Services, Inc. 

No 20-CH-05007 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Burt, et al. v. Anixter Inc, et al. 

No. 19-CH-04569 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Cameron, et al. v. Polar Tech Industries, Inc., et al. 

No. 19-CH-000013 (Circuit Court of DeKalb County, Chancery Division, State of Illinois) 

x Campbell, et al. v. Oberweis Dairy, Inc. 

No. 21-CH-02586 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Campos, et al. v. City View Multicare Center, LLC 

No. 19-CH-07082 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Campos, et al. v. Midwest Time Recorder, Inc. 

No. 19-CH-07229 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Chatman, et al. v. Crate and Barrel 

No. 18-CH-09277 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Coleman, et al v. Greenwood Hospitality Management, LLC

No. 21-cv-00806 (United States District Court for the Northern District of Illinois) 

x Cosenza v. DiNico’s Pizza, et al. 

No. 20-CH-00614 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Cothron v. White Castle, et al. 

No. 19-cv-00382 (United States District Court for the Northern District of Illinois) 

x Currie, et al. v. McDonald’s 

20-CH-0467 (Circuit Court of Lake County, Chancery Division, State of Illinois) 

x Davis, et al. v. Wirco, Inc. 

No. 21-cv-02279 (United States District Court for the Central District of Illinois)

x Delgado, et al. v. America’s Auto Auction Chicago, Inc. 

No. 19-CH-04164 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Doporcyk, et al. v. Mariano’s 

No. 17-CH-08092 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Duarte, et al. v. Vanee Foods Company

No. 21-CH-01318 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Ebert, et al. v. Eclipse Advantage, LLC

No. 2020-L-53 (Circuit Court of Grundy County, Law Division, State of Illinois) 

x Ebert, et al. v. Total Staffing Solutions, Inc.

No. 2021-CH-04338 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Edmond, et al. v. E.A. Sween Company 

No. 2022-CH-000027 (Circuit Court of DuPage County, Chancery Division, State of Illinois) 

x Festherson, et al. v. Krispy Kreme Doughnut Corp.

No. 2022-CH-01161 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Fields, et al. v. Abra Auto Body & Glass 

No. 17-CH-12271 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Figueroa, et al. v. Kronos, Inc. 

No. 19-cv-01306 (United States District Court for the Northern District of Illinois) 

x Figueroa, et al. v. Tony’s Fresh Market, et al. 

No. 18-CH-15728 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

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x Finley, et al. v. Clark Manor 

No. 20-CH-07265 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Fisher, et al. v. HP Property Management, LLC, et al. 

No. 19-CH-14082 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Francois v. South Shore Hospital, Corp. 

No. 21-CH-02564 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Francois, et al. v. Swipeclock, LLC 

No. 2022-CH-01041 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Fuentes, et al. v. Focal Point Exports, LTD., et al. 

No. 19-CH-03890 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Fulton, et al. v. SCR Medical Transport, Inc. 

No. 20-CH-00927 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Garriott, et al. v. Food Movers Two Limited Partnership 

No. 20-CH-07030 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Gates, et al. v. Eagle Family Foods Group, LLC 

20-CH-00478 (Circuit Court of Lake County, Chancery Division, State of Illinois) 

x Gates, et al. v. Thermoflex, et al. 

20-CH-00479 (Circuit Court of Lake County, Chancery Division, State of Illinois) 

x George, et al. v. Bricton 191 Associates, LLC, et al. 

No. 19-CH-04014 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Gniecki v. Columbia Sussex Management, LLC 

No. 21-CH-00677 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Goings, et al. v. UGN, Inc. 

No. 17-CH-14954 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Gray, et al. v. Waste Management of Illinois, et al. 

No. 2022-CH-02148 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Gray, et al. v. Brittlan II, LLC 

No. 2021-CH-05526 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Heard, et al v. Becton, Dickinson & Company 

No. 19-cv-4158 (United States District Court for the Northern District of Illinois) 

x Heard, et al. v. Omnicell, Inc. 

No. 19-CH-06817 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Heard, et al. v. St. Bernard Hospital, et al. 

No. 17-CH-16828 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Heard, et al. v. Weiss Memorial Hospital Foundation 

No. 19-CH-06763 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Hogan, et al. v. Amazon.com, Inc.

No. 21-cv-3169 (United States District Court for the Northern District of Illinois) 

x Howe, et al. v. Speedway, LLC

No. 19-cv-01374 (United States District Court for the Northern District of Illinois) 

x Ibarra, et al. v. Prospera, LLC, et al.

No. 20-CH-000562 (Circuit Court of DuPage County, Chancery Division, State of Illinois)

x Ingram, et al. v. LSL Healthcare 

No. 21-CH-00220 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Jacobs, et al. v. Wisenet 

No. 21-CH-00438 (Circuit Court of Cook County, Chancery Division, State of Illinois)

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x Johns, et al. v. Paycor, Inc. 

No. 20-L-000114 (Circuit Court of Madison County, Chancery Division, State of Illinois) 

x Johnson, et al. v. OM Joliet Wings, Inc. 

No. 20-CH-692 (Circuit Court of Will County, Chancery Division, State of Illinois) 

Johnson, et al. v. Gold Standard Baking, Inc., et al 

No. 18-CH-09011 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Johnson, et al. v. Fieldwork, Inc. 

No. 19-CH-11092 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Johnson, et al. v. Handi-Foil Corp., et al. 

No. 2021-CH-05931 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Kardos, et al. v. ABT Electronics, Inc. 

No. 19-CH-01235 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Keene, et al. v. Plymouth Place, Inc., et al. 

No. 19-CH-01953 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Kelley, et al. v. Chicago Behavioral Hospital, et al. 

No. 20-CH-03302 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x King, et al. v. Garfield Park Hospital, LLC 

No. 20-CH-00056 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Krause, et al. v. Caputo’s New Farm Produce, et al. 

No. 18-Ch-11660 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Landa, et al. v. Menasha Packaging Co., LLC 

20-CH-05251 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Landa, et al. v. MJ Holding Company, LLC 

20-CH-05247 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Lawrence, et al. v. McLane/Midwest, Inc. 

No. 2021-L-000061 (Circuit Court of Vermilion County, Law Division, State of Illinois) 

x Littleton, et al. v. Lydia Healthcare I, LLC 

No. 19-CH-12142 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Lopez, et al. v. Metraflex 

No-CH-05354 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Lorenz, et al. v. Morris Hospital and Healthcare Centers

No. 21-L-2 (Circuit Court of Grundy County, State of Illinois) 

x Loving, et al. v. Belhaven Nursing & Rehabilitation Center, LLC 

No. 20-CH-04176 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Marquez, et al. v. North Riverside Golf Club 

No. 20-CH-05895 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Mazya, et al. v. Northwestern Lake Forest Hospital, et al. 

No. 18-CH-07161 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x McGraw, et al. v. Lakeshore Beverage, et al. 

No. 20-CH-00343 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Measaw, et al. v. Heritage Operations Group, LLC 

No. 19-CH-08321 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Meegan, et al. v. NFI Industries, Inc. 

No. 20-cv-00465 (United States District Court for the Northern District of Illinois)

x Mendenhall, et al. v. Burger King 

No. 19-CH-10636 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

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x Mendez, et al. v. United Dental Partners, LLC, et al. 

No. 20-CH-01581 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Michaels, et al. v. Infinity Healthcare Management of Illinois, LLC

No. 2021-CH-05859 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Miller, et al. v. Communications Test Design, Inc. 

No. 20-CH-04284 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Mitchell, et al. v. Bottled Blonde Chicago, LLC 

No. 20-cv-06460 (United States District Court for the Northern District of Illinois) 

x Molina, et al. v. Mercyhealth System, Corp. 

No. 20-L-0000286 (Circuit Court of Winnebago County, Law Division, State of Illinois) 

x Morgan, et al. v. Ruler Foods, Inc. 

No. 20-cv-01270 (United States District Court for the Southern District of Illinois) 

x Morris, et al. v. Nextep Systems, Inc. 

No. 21-cv-2404 (United States District Court for the Northern District of Illinois) 

x Morris, et al. v. Wow Bao, LLC 

No. 17-CH-12029 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Mosby, et al. v. The Ingalls Memorial Hospital, et al. 

No. 18-CH-05031 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Naughton, et al. v. Amazon, Inc., et al.

No. 19-cv-06485 (United States District Court for the Northern District of Illinois) 

x Nelson, et al. v. Kid’s Castle Learning Center 

No. 20-L-000068 (Circuit Court of Sangamon County, Law Division State of Illinois) 

x Nordstrom, et al. v. Dial Senior Management, Inc. 

No. 19-CH-11108 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Nosal, et al. v. Rich Products Corporation, et al. 

No. 20-cv-4972 (United States District Court for the Northern District of Illinois) 

x Ortiz, et al v. Swiss Automation, Inc. 

No. 21-CH-02901 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Osborne, et al. v. WeWork Companies, Inc., et al. 

No. 19-cv-08374 (United States District Court for the Northern District of Illinois) 

x Parsons, et al. v. Personnel Staffing Group, LLC 

No. 20-CH-00473 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Peaks-Smith, et al. v. Saint Anthony Hospital, et al. 

No. 18-CH-07077 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Peatry, et al. v. Bimbo Bakeries USA, Inc. 

No. 19-cv-02942 (United States District Court for the Northern District of Illinois) 

x Peoples, et al. v. Avondale Estates of Elgin, LLC 

No. 2021-CH-05927 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Peoples, et al. v. Wheaton Village Nursing and Rehabilitation Center, LLC 

No. 2021-L-001234 (Circuit Court of DuPage County, Law Division, State of Illinois) 

x Pruitt, et al. v. Par-A-Dice Hotel Casino, et al. 

No. 20-cv-01084 (United States District Court for the Central District of Illinois) 

x Purnell, et al. v. Pure’s Food Specialties, LLC, et al. 

No. 21-CH-00991 (Circuit Court of Lake County, Chancery Division, State of Illinois)

x Quentere, et al. v. G.H. Cretors 

No. 20-cv-07306 (United States District Court for the Northern District of Illinois) 

Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 31 of 37 PageID #:4124
x Quentere, et al. v. Staffing Network, LLC 

No. 20-CH-00000654 (Circuit Court of Lake County, Chancery Division, State of Illinois) 

x Quentere, et al. v. Tablecraft Product Company, Inc. 

No 20-CH-00000493 (Circuit Court of Lake County, Chancery Division, State of Illinois) 

x Ramsey, et al. v. Daley’s Medical Transportation, Inc. 

No. 18-CH-01935 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Redd, et al. v. Amazon.com, Inc. 

No. 20-cv-06485 (United States District Court for the Northern District of Illinois) 

x Redd, et al. v. Wonolo, Inc. 

No. 22-cv-00292 (United States District Court for the Northern District of Illinois) 

x Robertson, et al. v. Hostmark Hospitality Group, Inc., et al. 

No. 18-CH-05194 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Rogers, et al. v. Thorek Memorial Hospital 

No. 21-CH-02304 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Ross, et al. v. Paylocity Corporation 

No. 2021-CH-06418 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Ross, et al. v. Sudler Property Management, Inc. 

No. 2021-CH-06416 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Sanchez, et al v. Elite Labor Services 

No. 18-CH-02651 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Sanchez, et al. v. Tide Cleaners

No. 20-CH-02640 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Seaton, et al. v. Atos Healthcare Services, LLC, et al. 

No. 21-CH-00611 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Severinsen, et al. v. Menard, Inc. 

No. 2022-CH-0000009 (Circuit Court of Peoria County, Chancery Division, State of Illinois) 

x Singleton, et al. v. B.L. Downey Company, LLC 

No. 21-cv-00236 (United States District Court for the Northern District of Illinois)

x Taitts, et al. v. Elior, Inc. 

No. 20-CH-03664 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x In Re: TikTok, Inc., Consumer Privacy Litigation 

No. 20-cv-04699 (United States District Court for the Northern District of Illinois)

x Thome, et al. v. Axis Insurance Company, et al. 

No. 2021-CH-03259 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Thornton, et al. v. Generations at Peoria, LLC, et al. 

No. 21-CH-03481 (Circuit Court of Cook County, Chancery Division, State of Illinois)

x Tims, et al. v. Black Horse Carriers, Inc. 

No. 19-CH-03522 (Circuit Court of Cook County, Chancery Division, State of Illinois) 

x Toor, et al. v. CoreCentric Solutions, Inc. 

No. 19-CH-05914 (Circuit Court of DuPage County, Chancery Division, State of Illinois) 

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Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 32 of 37 PageID #:4125
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Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 33 of 37 PageID #:4126
Exhibit 

Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 34 of 37 PageID #:4127
Firm Name:

Categories: TITLE:

ATTORNEYS(P, A)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 PREVIOUS HOURS CURRENT 

HOURS

CUMULATIVE 

HOURS

James Zouras (P) 8.30 8.40 13.90 34.90 35.40 0.30 0.00 0.00 7.20 1.80 49.30 25.00 1.00 0.00 0.00 0.00 185.50 185.50 Ryan Stephan (P) 0.30 3.50 1.10 2.60 4.50 0.00 0.00 0.00 0.30 0.00 6.60 17.10 0.00 0.00 0.00 0.00 36.00 36.00 

Katie Mitchell (P) 0.00 0.40 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.40 0.40 

Andrew Fickzo (P) 0.20 1.80 14.20 9.70 10.50 0.20 0.00 0.00 0.00 0.00 4.80 2.80 0.00 0.00 0.00 0.00 44.20 44.20 Megan Shannon (A) 4.30 10.60 31.80 3.60 42.10 0.00 0.00 0.00 0.00 0.00 22.90 7.30 0.00 0.00 0.00 0.00 122.60 122.60 

Paige Smith (A) 0.00 0.00 0.00 0.00 2.20 0.00 0.00 0.00 0.00 0.00 10.10 0.10 0.00 0.00 0.00 0.00 12.40 12.40 

0.00 0.00 0.00 

0.00 0.00 0.00 

SUB-TOTAL 13.10 24.70 61.00 50.80 94.70 0.50 0.00 0.00 7.50 1.80 93.70 52.30 1.00 0.00 0.00 0.00 401.10 401.10 

NON-ATTORNEYS(LC, SPL, PL)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 PREVIOUS HOURS CURRENT 

HOURS

CUMULATIVE 

HOURS

Jesica Ortiz-Acosta (PL) 0.00 0.00 0.00 0.40 8.00 0.00 0.00 0.00 0.00 0.00 0.00 1.70 0.00 0.00 0.00 0.00 10.10 10.10 Lynn Clark (PL) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.50 0.00 0.00 0.00 0.00 1.50 1.50 

Kerry Bowers (SPL) 0.00 0.20 0.00 3.00 0.20 0.00 0.00 0.00 0.00 0.00 3.90 1.20 0.00 0.00 0.00 0.00 8.50 8.50 Emily Barraza (PL) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.50 0.00 0.00 0.00 0.00 0.50 0.50 

Monica Almeida (PL) 1.00 0.50 0.00 1.80 3.40 0.00 0.00 0.00 0.00 0.00 24.30 2.10 0.00 0.00 0.00 0.00 33.10 33.10 

0.00 0.00 0.00 

0.00 0.00 0.00 

0.00 0.00 0.00 

0.00 0.00 0.00 

0.00 0.00 0.00 

0.00 0.00 0.00 

SUB-TOTAL 1.00 0.70 0.00 5.20 11.60 0.00 0.00 0.00 0.00 0.00 28.20 7.00 0.00 0.00 0.00 0.00 53.70 53.70 

GRAND TOTAL: 14.10 25.40 61.00 56.00 106.30 0.50 0.00 0.00 7.50 1.80 121.90 59.30 1.00 0.00 0.00 0.00 454.80 454.80 

1) Legal Research2) Investigation / Factual Research3) Discovery 

(Written / Deposition Taking & 

Defending / Meet & Confer / etc. )

4) Document Review

(Including for depo prep, class cert,experts, liability issues, jurisdictional issues, and meetings re doc review)

5) Pleadings, Briefs & Motions (Drafting, Research, Serving & Filing)6) Class Certification7) Summary Judgment8) Appeals9) Court Appearance and Prep10) Experts 

11) Settlements & Mediation12) Case Management13) Class Notice14) Trial Prep 

(Exhibit & Witness List/Jury Instruction/Vior Dire/Opening Statements/Closing Arguments/Demonstratives/etc.)

15) Trial

(P(A

(L

(S(P

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 1

TIME REPORT SUMMARY AT &855(17 RATES

Stephan Zouras, LLP. Reporting Period: Inception through )HEUXDU\

 556281 

Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 35 of 37 PageID #:41
Exhibit 

Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 36 of 37 PageID #:4129
CATEGORY DESCRIPTION 

(If necessary) CUMULATIVE COSTS

Litigation Assessment

Court Costs - Filing Fees

Complaint filing fee paid to 

the Northern District of IL on 

5/20/20 $400.00

Experts/consultants

Check #12222 made payable 

to River Sonic Solutions for 

BIPA consultation from 

4/1/2019 - 3/31/2020; 

4/20/20 - 8/27/20 $729.32

Federal Express / UPS /Ontrac

Postage / U.S. Mail

Service of Process

Invoice #258101 paid to 

Judicial Attorney Services 

for service and attempted 

service on all 4 defendants. $556.40

Messenger/delivery

Hearing Transcripts

Investigation

Payment to Cook County 

Chancery Division for copies 

of Final Approval Memo 

from case Prelipceanu v. 

Jumio/Pacer Research for Q3 $72.57

Lexis/westlaw Westlaw research $44.82

Photocopies - in House

Photocopies - Outside

Telephone/telecopier

Travel - Transportation

(Airplanes - Coach Fares Only)

Travel - Meals

($75 per person / day cap)

Travel - Hotels

Miscellaneous Conference line charges $5.79

TOTAL EXPENSES $1,803.11

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2 

EXPENSE REPORT SUMMARY

FIRM NAME: Stephan Zouras, LLP. 

REPORTING PERIOD: Inception through )HEUXDU\

 556281 Ex 2 Expense Summary

Case: 1:20-cv-04699 Document #: 197-34 Filed: 03/31/22 Page 37 of 37 PageID #:4130