EXHIBIT AA 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 1 of 17 PageID #:4465
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 CASEY C. DEREUS IN SUPPORT OF PLAINTIFFS’ PETITION 

FOR AWARD OF ATTORNEYS’ FEES FILED ON BEHALF OF BAER LAW, LLC 

 I, Casey C. Dereus, declare and state as follows: 

1. I am an Associate of the law firm of Baer Law, LLC. 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: Identifying the BIPA claim and the initial BIPA claimants in this action nationwide; 

researching and drafting the initial complaint, and coordinating with class representatives about 

their claims, settlement discussions, and their claim forms. The total number of hours expended 

on this litigation by my firm from case inception through October 31, 2020, is 53.50 hours. The 

total lodestar for my firm in this time period is $22,644.00. 

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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: N/A. 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 0 hours. The total lodestar 

for my firm in this time period is $0. 

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

inception through February 28, 2022, is 69.90 hours. The total lodestar for my firm is $$29,549.00. 

My firm’s lodestar figures are based on the firm’s current hourly billing rates. The hourly rates for 

the partners, 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 Co-Lead 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 current hourly billing 

rates from case inception through February 28, 2022. 

6. As detailed in Exhibit 3, my firm has incurred a total of $0 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. 

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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.

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 23rd day of March 2022 at New Orleans, Louisiana.

_____________________________

Casey C. DeReus

_____________________________

Casey C. DeReus

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Exhibit 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 5 of 17 PageID #:4469
 

BAER LAW LLC

3000 Kingman Street, Suite 200

Metairie, LA 70006

504.372.0111 | info@baerlawllc.com

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 ABOUT US Baer Law LLC is a boutique law firm that focuses on catastrophic personal injury cases, negligent security, 

and post-disaster insurance recovery. We have a reputation for preparing every case for trial, and our 

attorneys have handled countless trials in state and federal courts. We’ve also handled high-volume and 

class action matters, including mass-consolidated property insurance claims; In Re Taxotere (Docetaxel) 

2:16md-2740-JTM-MBM; In Re: Chinese Manufactured Drywall Products Liability Litigation (E.D. La. 

2010); etc. 

Baer Law attorneys have built their careers helping personal injury victims and wrongful death and 

survival claimants get the money they are owed in high-stakes, contested-liability cases. We are a leading 

litigation and trial firm in the Gulf South. 

Each attorney’s profile is included below.

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 7 of 17 PageID #:4471
Jason M. Baer 

Founder and Managing Partner 

Jason Baer is the founder and Managing Partner of Baer Law LLC. Jason has a reputation in the Louisiana 

legal community as an aggressive litigator, a shrewd negotiator, and a successful trial lawyer. 

Over the past few years, Jason has developed a thriving personal injury practice. In fact, leading attorneys 

throughout Louisiana seek Jason out to co-counsel with them on complicated, high-stakes trucking, 

negligent security, and commercial motor vehicle collision cases. 

Prior to founding Baer Law, Jason was a Partner at a local New Orleans plaintiff’s firm, where he not only 

led the Personal Injury Division, but also worked on more than 800 property insurance cases for Louisiana 

policyholders. 

Jason’s background is part of what has made him so successful as a “lawyer’s lawyer.” After almost ten 

years as a successful defense attorney, Jason made the switch to the plaintiff side. Since that time, Jason 

has used his defense background—and especially his background in defending large trucking casualty 

cases—to outmaneuver his opponents in both personal injury and first-party property cases. Because 

Jason has extensive experience doing defense work, he’s able to anticipate insurance companies’ 

arguments and head them off. 

Currently, Jason focuses his practice on trucking and transportation casualty, premises liability, and 

negligent security cases. He also handles complex insurance coverage matters. Jason has successfully 

litigated complex cases involving catastrophic injuries and has secured favorable settlements and verdicts 

for his clients in state and federal court. 

Mr. Baer has been recognized by Super Lawyers as a Rising Star, by the American Institute of Personal 

Injury Attorneys as one of the 10 Best in Client Satisfaction, by Attorney and Practice Magazine as a Top 

10 Personal Injury Attorney, by the National Academy of Personal Injury Attorneys in their Top 10 Under 

40, by the National Trial Lawyers: Top 100 Trial Lawyers, as well as their Top 40 under 40, by the 

Lawyers of Distinction, and by both the Million 

Dollar Advocates Forum and Multi-Million Dollar 

Advocates Forum. Also, New Orleans 

CityBusiness chose Jason for their 2020 

Leadership in Law class, recognizing area 

professionals in the field of law for their career and 

community accomplishments. 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 8 of 17 PageID #:4472
EDUCATION 

 Juris Doctor, Loyola University College of Law.

 Bachelor of Science, Louisiana State University.

BAR AND COURT ADMISSIONS 

 Louisiana State Bar, Federal Court Admissions: U.S. District Court for the Eastern District of 

Louisiana, U.S. District Court of the Middle District of Louisiana, U.S. District Court for the 

Western District of Louisiana, U.S. District Court for the Southern District of Texas, Louisiana 

Notary Public. 

PROFESSIONAL ASSOCIATIONS AND MEMBERSHIPS 

 Federal Bar Association, Board Member of Young Lawyers Section (2012-2014), American Bar 

Association, Louisiana State Bar Association, Board Member of Young Lawyers Section (2012-

2014), Jefferson Bar Association, Board Member of Young Lawyers Section, (2013-2014), Claims 

& Litigation Management Alliance, Louisiana Association of Defense Counsel, Louisiana 

Association for Justice, Defense Research Institute, Young Leadership Council, New Orleans, 

Greater New Orleans Sports Foundation, Board Member (2010- 2013), Mentor for Jesuit High 

School Mock Trial Program (2010-2012) 

PUBLICATIONS 

 “Diminished Value Claims in Louisiana,” New Orleans Bar Association Blog Post, May 20, 2020. 

AWARDS

 Super Lawyers Rising Star. 

 American Institute of Personal Injury Attorneys, 10 Best in Client Satisfaction. 

 Attorney and Practice Magazine, Top 10 Personal Injury Attorney. 

 The National Academy of Personal Injury Attorneys Top 10 Under 40. 

 The National Trial Lawyers Top 100 Trial Lawyers and Top 40 under 40. 

 The Lawyers of Distinction Recognition. 

 Million Dollar Advocates Forum Recognition. 

 Multi-Million Dollar Advocates Forum Recognition. 

 New Orleans City Business, Leadership in Law, Class of 2020. 

 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 9 of 17 PageID #:4473
Casey C. Dereus 

Associate 

Casey is an Associate with Baer Law. Attorneys in the greater New Orleans area come to Casey for help 

on complicated legal matters and for her writing skills. She is known as a smart, thorough, and hardworking advocate. 

Casey moved to New Orleans in 2010 and fell in love with the city. She attended graduate school at 

Tulane where she earned her Master’s and met her husband. Later, Casey attended law school at Loyola 

University New Orleans College of Law where she served as Managing Print Editor on the Loyola Law 

Review and graduated magna cum laude. 

Since graduating, Casey has been a devoted personal injury attorney and first-party property attorney. 

Before starting with Baer Law, LLC, Casey focused on property insurance claims and personal injury 

cases. In fact, in her first few years out of law school, she handled more than 1,000 first-party property 

cases, including business interruption claims and flood insurance and hurricane claims. Her experience 

includes handling Hurricane Sandy claims, Hurricane Harvey claims, and flood insurance claims from the 

2016 Louisiana floods. 

Although Casey is interested in many areas of the law, she currently focuses her personal injury practice 

on motor vehicle crash cases (especially those involving ride-sharing services like Uber and Lyft), 

negligent security cases (especially involving third-party criminal actors), and livestock personal injury 

cases (such as when escaped cattle or other animals become involved in car wrecks). She also continues 

to handle post-disaster property damage & business interruption cases, including Coronavirus cases. 

Recently, Casey also developed a class action lawsuit against TikTok for violations of privacy laws, 

resulting in a $92 million proposed settlement. 

Casey is knowledgeable about how climate change is affecting property 

insurance. She is proud of her past service as a member of the American 

Bar Association’s Disaster Legal Services Program. The ABA’s Disaster 

Legal Services Program provides immediate temporary legal assistance 

to disaster survivors at no charge. She also volunteers as the Women’s 

Caucus Publications Chair for the Louisiana Association of Justice. 

She has been recognized by Super Lawyers as a Rising Star, and by the 

National Trial Lawyers in their Top 40 Under 40. Casey is fluent in 

French and can accommodate clients from France or other Francophone 

countries. 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 10 of 17 PageID #:4474
EDUCATION 

 Juris Doctor, Loyola University of New Orleans. 

 Master of Arts, Tulane University. 

 Bachelor of Arts, College of William and Mary. 

BAR AND COURT ADMISSIONS

 Louisiana State Bar; Federal Court Admissions: U.S. District Court for the Eastern District of 

Louisiana, U.S. District Court for the Middle District of Louisiana, U.S. District Court for the 

Western District of Louisiana, U.S. District Court for the Southern District of Texas, U.S. Court 

of Appeals for the Fifth Circuit; Louisiana Notary Public. 

PROFESSIONAL ASSOCIATIONS AND MEMBERSHIPS

 Louisiana State Bar Association, American Bar Association: YLD DLS Team Member (2018-

2021), YLD Vice Chair of the Solo, Small Firm, and General Practice Committee (2019-2020), 

Louisiana Association for Justice: Chair of Women’s Caucus Publications Committee (2019-

Present), American Association for Justice, Federal Bar Association, Jefferson Bar Association. 

PUBLICATIONS

 “Inclusion in Action: LSBA Suit Up for the Future High School Summer Legal Institute and 

Internship Program,” The Advocate, Winter Edition 2022, Vol. 31, No. 2, Federal Bar Association, 

New Orleans Chapter. 

 “Don’t Fall for this Defense Trick! | How Dismissal Affects Prescription Under Current La. C.C. 

Article 3463,” Louisiana Advocates, Aug. 2021, Vol. XXXXVI, No. 8. 

 “Time for a change? Rule 1.10 and the General Rule for Imputations of Conflicts of Interest,” 

Louisiana Advocates, June 2021, Vol. XXXVI, No. 6. 

 “‘Qualification’ Under F.R.E. 702: Fifth Circuit v. Eleventh Circuit Perspectives,” The Advocate, 

Spring Edition, Vol. 30, No. 3. 

 “Louisiana Fourth Circuit vacates dismissal on prescription grounds, remands case,” Louisiana 

Advocates, February 2021, Vol. XXXVI, No. 2. 

 “Getting it right: properly issuing a subpoena under FRCP 45,” Louisiana Advocates, September 

2020, Vol. XXXV, No. 9. 

 “The rear-end presumption and how to rebut it,” Louisiana Advocates, January 2020, Vol. XXXV, 

No. 1. 

 “Piercing the Corporate Veil with the Single Business Enterprise Doctrine,” Louisiana Bar Journal, 

August/September 2019, Vol. 67, No. 2. 

 “What’s fair game in a 30(b)(6) deposition? Almost everything!” Louisiana Advocates, March 

2019, Vol. XXXIV, No. 3. 

 “Suing for Punitive Damages Under Another State’s Law,” Louisiana Advocates, July 2018, Vol. 

XXXIII, No. 7. 

 “Bozeman and the Dual Nature of the Collateral Source Rule,” Louisiana Advocates, February 

2018, Vol. XXXIII, No. 2. 

AWARDS 

 Super Lawyers Rising Stars (2020-2022), The National Trial Lawyers Top 40 Under 40 (2020) 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 11 of 17 PageID #:4475
Joshua A. Stein 

Associate 

Josh is an Associate with Baer Law. He has a background in personal injury and first-party property 

insurance cases. Since joining Baer Law, Josh has focused his career on personal injury, with practice 

areas ranging from motor vehicle crashes to premises liability issues. Josh has developed a reputation for 

successful resolution of major trucking casualty cases. Josh is also involved in a recently-filed class action 

and is building his maritime personal injury practice. His dedication to his clients and his perceptive 

negotiating tactics allow him to help clients resolve their claims in an efficient and favorable way. 

Josh was born and raised in New Orleans where he attended Brother Martin High School. Josh graduated 

from Loyola University New Orleans College of Law in 2017, receiving a certificate in International Legal 

Studies and being inducted into the Order of Barristers. While at Loyola, Josh had the honor to serve as 

the Vice President for the Student Bar Association and as the school’s representative to the American Bar 

Association. 

Josh also served as Vice President of the Loyola Trial Advocacy Program and competed twice on the 

program’s National American Association of Justice Competition team. He earned the Law Excellence 

Award in Civil Procedure and participated in the Stuart H. Smith Law Clinic, where he represented 

underprivileged defendants. Prior to attending Loyola, he graduated from Louisiana State University with 

a Bachelor’s Degree in Political Science. 

Josh is a respected speaker and makes it a priority to engage with the legal community. He has presented 

on the topic of “Case Management Platforms and Programs: A Pros and Cons Shootout for the Small 

Office Practitioner” with LSBA’s Tech Tuesday Legal Program in August of 2021. Additionally, Josh 

was a panelist of the “Doctor Depositions” CLE in December 2019 and the “Managing Medicals to 

Maximize Settlements” CLE in June 2019. 

He has been recognized by Super Lawyers as a Rising Star, the National Trial Lawyers in their Top 40 

Under 40 and America’s Top 100 Personal Injury Attorneys. 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 12 of 17 PageID #:4476
EDUCATION

 Juris Doctor, Loyola University New Orleans College of Law. 

 Bachelor of Arts, Louisiana State University. 

BAR AND COURT ADMISSIONS 

 Louisiana State Bar. 

 Federal Court Admissions: U.S. District Court for the Eastern District of Louisiana, U.S. District 

Court for the Middle District of Louisiana, U.S. District Court for the Western District of 

Louisiana. 

 Serves as Louisiana Notary Public. 

PROFESSIONAL ASSOCIATIONS AND MEMBERSHIPS 

 Louisiana State Bar Association. 

 Federal Bar Association. 

 American Association for Justice. 

 American Bar Association. 

 Jefferson Bar Association. 

 Louisiana Association for Justice. 

 Young Leadership Council New Orleans. 

PUBLICATIONS 

 “The Quest for the Holy Grail (of Case Management Platforms),” New Orleans Bar Association 

Blog Post (January 2021). 

AWARDS 

 Super Lawyers Rising Stars (2020-2022).

 The National Trial Lawyers Top 40 Under 40 (2019).

 America’s Top 100 Personal Injury Attorneys (2020).

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 13 of 17 PageID #:4477
Exhibit 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 14 of 17 PageID #:4478
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

HOUR

RAT

Casey C. DeReus (A) 11.20 6.40 0.30 0.00 6.80 0.00 0.00 0.00 0.00 0.00 4.90 14.10 0.00 0.00 0.00 0.00 43.70 43.70 $400

Jason M. Baer (P) 2.40 0.20 0.00 0.00 2.50 0.00 0.00 0.00 0.00 0.00 1.20 5.20 0.00 0.00 0.00 0.00 11.50 11.50 $550

Joshua A. Stein (A) 0.10 0.10 0.70 0.00 2.90 0.00 0.00 0.00 0.00 0.00 4.00 6.50 0.00 0.00 0.00 0.00 14.30 14.30 $400

0.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.0

SUB-TOTAL 13.70 6.70 1.00 0.00 12.20 0.00 0.00 0.00 0.00 0.00 10.10 25.80 0.00 0.00 0.00 0.00 69.50 69.50 

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

HOUR

RAT

Dana Ward (SPL) 0.40 0.00 0.40 0.40 $60.

0.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.0

SUB-TOTAL 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 GRAND TOTAL: 13.70 7.10 1.00 0.00 12.20 0.00 0.00 0.00 0.00 0.00 10.10 25.80 0.00 0.00 0.00 0.00 69.90 69.90 

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 Notice 14) Trial Prep  (Exhibit & Witness List/Jury Instruction/  Vior Dire/Opening Statements/Closing  Arguments/Demonstratives/etc.)15) Trial

(P) Par(A) Ass(LC) L(SPL) S(PL) Pa

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 1

TIME REPORT SUMMARY AT CURRENT RATES

Baer Law, LLC Reporting Period: Inception through February 28, 2022

 556281 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 15 of 17 PageID #:44
Exhibit 

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 16 of 17 PageID #:4480
CATEGORY CUMULATIVE COSTS

Litigation Assessment $0.00

Court Costs - Filing Fees $0.00

Experts/consultants $0.00

Federal Express / UPS /Ontrac $0.00

Postage / U.S. Mail $0.00

Service of Process $0.00

Messenger/delivery $0.00

Hearing Transcripts $0.00

Investigation $0.00

Lexis/westlaw $0.00

Photocopies - in House $0.00

Photocopies - Outside $0.00

Telephone/telecopier $0.00

Travel - Transportation

(Airplanes - Coach Fares Only) $0.00

Travel - Meals

($75 per person / day cap) $0.00

Travel - Hotels $0.00

Miscellaneous $0.00

TOTAL EXPENSES $0.00

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2 

EXPENSE REPORT SUMMARY

FIRM NAME: 

REPORTING PERIOD: Inception through February 28, 2022

 556281 Ex 2 Expense Summary

Case: 1:20-cv-04699 Document #: 197-44 Filed: 03/31/22 Page 17 of 17 PageID #:4481