EXHIBIT Z 

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Exhibit 

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OnderLaw, LLC is a preeminent law firm with offices in St. Louis, Missouri, Newport Beach, 

California, and Nashville, Tennessee. We are proud to represent victims of dangerous and 

defective products and corporate fraud throughout the United States. As founders of important 

litigations, including mini blinds and talcum powder-related ovarian cancer claims, we take great 

pride in creating positive change for generations to come. Our accomplished team of 29 

attorneys and over 150 dedicated staff members believes our job goes beyond providing 

expertise and legal experience. With every case we represent, we are changing the way people 

and corporations think, act, and do business—for the better. 

The firm has earned a Martindale-Hubbell AV peer review rating; has multiple members serving 

on the board of governors of the Missouri Association of Trial Attorneys; achieved a Super 

Lawyers designation; is a member of the Multi-Million Dollar Advocates Forum, The American 

Society of Legal Advocates, and National Trial Lawyers Top 100 Trial Lawyers; and has 

received the National Litigator Award, among numerous additional recognitions. 

OnderLaw, LLC was founded in 2002, and has since earned a prominent reputation among trial 

lawyers nationwide as a successful, skilled, and passionate law firm. In 2016, the firm was 

awarded the first, second, and third largest verdicts in the state of Missouri, and the third-highest 

verdict the following year. In total, OnderLaw has won more than $4 billion in settlements, 

verdicts, and judgments representing the interests of our clients. 

OnderLaw, LLC has extensive experience handling complex litigation. Law firms across the 

country utilize the decades of hard-earned experience by OnderLaw, LLC’s attorneys in a variety 

of contexts, including representing clients in cases involving toxic chemicals, dangerous and 

defective drugs and medical devices, and deceptive marketing practices. The firm has handled to 

conclusion hundreds of catastrophic injury and death product liability claims against some of the 

nation’s largest corporations and industries involving mini blinds, automobiles, trucks, forklifts, 

tires, and cranes. 

OnderLaw, LLC has the resources necessary, including a large team of diverse and capable 

attorneys and support staff, to advance complex litigation in a timely fashion. The firm also has 

the financial wherewithal needed to pursue large-scale, complex actions. With a proven record of 

accomplishments in Missouri, Illinois, California, Tennessee, and several other states, 

OnderLaw, LLC has aptly earned its status among the top 1% of law firms in the country. 

REPRESENTATIVE LITIGATION

The following cases are representative samples of the types of cases OnderLaw, LLC’s attorneys 

have handled since the firm’s formation in 2002: 

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In re: Talcum Powder-Related Ovarian Cancer Litigation – MDL No. 2738 United States 

District Court District of New Jersey; JCCP No. 4872 California Superior Court for Los Angeles 

County; MCL 300 New Jersey Vicinage 1 Superior Court; State of Missouri City of St. Louis 

Circuit Court; St. Louis County Circuit Court; and Jefferson County Circuit Court.

OnderLaw is a founder of talcum powder-related ovarian cancer litigation. Our team filed the 

second case in the nation and the first in the State of Missouri in 2014, effectively creating 

Missouri ovarian cancer litigation. We currently represent 24,546 women who have suffered 

talcum powder-related cancer and their survivors. Ours is believed to be the largest such docket 

in the country. 

Among those we represent, over 500 cases are pending in Missouri courts, including the Circuit 

Courts of the City of St. Louis, St. Louis County and Jefferson County. Our team serves as 

primary or local counsel for the overwhelming majority of these cases. We have led six trial 

teams representing plaintiffs who have obtained verdicts totaling in excess of $300 million, and 

we are actively involved in New Jersey and California courts. 

In the New Jersey MDL, our team has been active on Bellwether, Expert, and Daubert 

Committees and participated in the Daubert hearing. Two clients we represent have been selected 

for bellwether workup and trial. 

In New Jersey consolidated litigation, our team serves on the Bellwether Trial Team with clients 

in both A and B trial groups. OnderLaw was among the earliest filers in New Jersey and assisted 

in the appeal of the early adverse expert witness ruling. 

OnderLaw’s legal team is active on the Plaintiff’s Steering Committee in the California JCCP, 

leading Bellwether, Expert and Sargon Committees. Two of our clients’ cases were selected for 

bellwether trials scheduled to be held in early 2022. 

In re: Imerys Talc America, Inc. Bankruptcy Litigation – No. 19-10289 United States 

Bankruptcy Court for the District of Delaware – In Imerys Talc America Bankruptcy, Case No.

19-10289 in United States Bankruptcy Court for the District of Delaware, OnderLaw, LLC 

serves as counsel for Timothy Faltus, a member of the Imerys Talc Creditors’ Committee. In 

doing so, we not only represent our client’s interests, but assist him in acting on behalf of tens of 

thousands of additional plaintiff creditors. 

In re: Bayer-Monsanto Roundup Coordinated Action – JCCP No. 4953 California Superior 

Court for the County of Alameda; MDL 2741 United States District Court for the Northern 

District of California; State of Missouri City of St. Louis Circuit Court, St. Louis County Circuit 

Court, Jackson County Circuit Court, and Jefferson County Circuit Court – OnderLaw, LLC is 

currently leading Missouri litigation and representing more than 24,000 plaintiffs from across the 

country who have been affected by multiple cancers, including non-Hodgkin’s lymphoma, 

suffered after long-term use of Roundup herbicide. 

In re: Syngenta Paraquat Product Liability Litigation – JJCP No. 5031 California Superior 

Court of Contra Costa County – Our team serves on the litigation’s Leadership Committee, 

acting on behalf of farmers and other agricultural workers with Parkinson’s disease allegedly 

caused by long-term use of Paraquat pesticide, a known neurotoxin. 

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In re: Tasigna (Nilotinib) Products Liability Litigation – MDL No. 3006 United States District 

Court for the Middle District of Florida – A dedicated OnderLaw attorney serves as national colead counsel on this litigation, acting on behalf of hundreds of individuals with atherosclerotic 

injuries or death allegedly caused by chronic myeloid leukemia drug Tasigna. 

In re: Truvada Products Liability Litigation – JCCP No. 5043 Superior Court of California, 

County of San Francisco – The OnderLaw legal team represents more than 9,000 clients against 

the makers of Truvada (tenofovir) for claims that the HIV prevention drug caused unnecessary 

bone loss and kidney damage. The OnderLaw legal team is taking on a leadership role on the 

Plaintiff’s Steering Committee. 

In re: Zantac Products Liability Litigation – JCCP No. 5150 California Superior Court for the 

County of Alameda – The firm is taking an active role on the Plaintiff’s Executive Committee 

and is currently representing over 8,700 plaintiffs and growing who developed several different 

types of cancer following long-term use of Zantac. 

In re: 3M Combat Arms Earplug Products Liability Litigation – MDL No. 2885 United States 

District Court for the Northern District of Florida – The firm represents approximately 2,000 

current and former military service members who suffered hearing loss and tinnitus following 

use of CAEv2 earplugs supplied by 3M to the U.S. military. Our client was chosen for the first 

bellwether trial and was awarded $2.26 million; a second OnderLaw client is expected to go to 

trial in spring 2022. 

In re: Yasmin and Yaz (Drospierenone) Marketing, Sales Practices, and Relevant Products 

Liability Litigation – MDL No. 2100 United States District Court for the Southern District of 

Illinois; JCCP No. 4608 Superior Court of the State of California County of Los Angeles – The 

firm held a position as national co-lead counsel, acting on behalf of over 10,000 individuals for 

injuries caused by oral contraceptives Yasmin, Yaz, and Ocella, including strokes, heart attacks, 

pulmonary embolism, deep vein thrombosis, and gallbladder injuries. Firm attorneys served as 

national co-chair of the Plaintiffs’ Law and Briefing Committee, as well as on Discovery, 

Science and Expert Committees for both the MDL and JCCP. A settlement of $2 billion was 

reached on behalf of the plaintiffs. 

In re: Pradaxa (Dabigatran Etexilate) Products Liability Litigation – MDL No. 2385 United 

States District Court for the Southern District of Illinois – Our team served as national co-liaison 

counsel, acting on behalf of thousands of individuals with injuries allegedly caused by 

prescription blood thinner, Pradaxa. The firm also served as national co-chair of the Plaintiffs’ 

Law and Briefing Committee. A settlement of $600 million was reached on behalf of the 

plaintiffs. 

In re: Gadolinium-Based Contrast Agents Product Liability Litigation – MDL No. 1909 United 

States District Court for the Northern District of Ohio – Firm attorneys served on Science and 

Expert Committees for plaintiffs who suffered kidney damage after injection of gadoliniumbased contrast agents prior to undergoing MRIs. 

Syngenta Corn Mass Action – The firm served as local and national coordinating council in a 

certified mass action based in United States District Court for the Southern District of Illinois

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representing farmers with nearly three million acres of affected corn, in coordination with 

multidistrict litigation and the coordinated action in Minnesota state courts. A settlement of $1.5 

billion was reached on behalf of the plaintiffs. 

In re: Trace Foster, et al. v. Pfizer, Inc., et al. – Firm attorney served as local liaison counsel in 

the multi-plaintiff Zoloft-related litigation in the Circuit Court of the City of St. Louis. This 

litigation involved allegations that mothers’ use of Zoloft while pregnant caused minor plaintiffs 

to suffer various birth defects. 

Lynne A. Booker, et al. v. Forest Laboratories, Inc., et al. (Consolidated Proceedings) –

OnderLaw, LLC attorneys played an active role in the coordination and consolidated discovery 

process for the benefit of the more than 100 plaintiffs who filed cases against the makers and 

sellers of the anti-depressant medication Lexapro. These cases, filed in Circuit Court of Cole 

County, Missouri, involved allegations that mothers’ use of Lexapro while pregnant caused 

minor plaintiffs to suffer various birth defects. 

Johnson, et al. v. Apple, Inc. – The firm represented a nationwide class in a consumer class 

action in the Superior Court of the State of California, County of Santa Clara against Apple, Inc. 

arising from allegations pertaining to the labeling of Apple’s iTunes Gift Cards and the pricing 

of songs on the iTunes website. 

Hedrick, et al. v. Ameristar Casino St. Charles, Inc. – 4:08-cv-1670 United States District Court 

for the Eastern District of Missouri – The firm assisted with the representation of a class of 

persons alleging violations of the Fair Labor Standards Act by Ameristar Casino. 

Alsup, et al. v. Three-Day Blinds, et al. – Firm attorneys pursued putative class action involving 

claims of deceptive marketing against the makers and sellers of mini blinds throughout the 

United States in the Circuit Court for the County of Madison, State of Illinois. 

In re: McAffee, et al. v. Domino’s, Inc., et al. – The firm represented a class of persons in the 

Circuit Court of City of St. Louis, State of Missouri alleging that Domino’s Pizza engaged in 

deceptive practices in conjunction with representations that it was offering “free delivery” of 

pizzas, while at the same time charging higher prices for these pizzas. 

In re: Bayer Corp. Combination Aspirin Products Marketing and Sales Practices Litigation – 

MDL No. 2023 United States District Court for the Eastern District of New York – Firm attorney 

served as a court-appointed member of the Plaintiffs’ Executive Committee for this consolidated 

class action relating to alleged deceptive marketing of the pharmaceutical products Bayer Aspirin 

with Heart Advantage and Bayer Low Dose Women’s Aspirin + Calcium. 

In re: Actos (Pioglitazone) – MDL No 2299 United States District Court for Western District of 

Louisiana; in re: Ortho Evra Product Liability Litigation, MDL No. 1742 United States District 

Court for the Northern District of Ohio; JCCP No. 4696 Los Angeles Superior Court –

OnderLaw, LLC attorneys represented plaintiffs in litigation on behalf of victims who suffered 

bladder cancer and heart problems after using Type 2 diabetes drug Actos. OnderLaw attorneys 

served on the MDL Science and Expert Committees, as well as the Plaintiffs’ Steering 

Committee in the JCCP. 

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In re: Fosamax Products Liability Litigation – MDL No. 2243 United States District Court for 

the District of New Jersey – Firm attorneys served on Science and Expert Committees for 

litigation resulting from failure to warn of the potential for Fosamax, a drug used to treat 

osteoporosis, to cause osteonecrosis of the jaw and femoral fractures. 

In re: Zoloft (Sertraline Hydrochloride) Products Liability Litigation – MDL No. 2342 United 

States District Court for the Northern District of California; and in re: Zoloft Birth Defect 

Litigation – JCCP No. 4771 United States District Court for the Eastern District of Pennsylvania 

– Firm attorneys served on Science, Expert, and Daubert Committees in the MDL and Plaintiffs’ 

Steering Committee in the JCCP while representing the interests of plaintiffs whose children 

were born with birth defects following maternal use of Zoloft anti-depressant while pregnant. 

In re: Vioxx Products Liability Litigation – MDL No. 1657 United States District Court Eastern 

District of Louisiana – OnderLaw, LLC attorneys served on the Science, Expert, and Daubert 

Committees while representing victims and their survivors in litigation against pharmaceutical 

maker, Merck, after arthritis drug Vioxx was linked to potentially fatal heart attacks and strokes. 

In re: Bextra and Celebrex Marketing, Sales Practices and Product Liability Litigation – MDL 

No. 1699 United States District Court for the Northern District of California – Firm attorneys 

represented victims and their survivors in litigation against Pfizer after Celebrex and its 

successor, Bextra, were linked to sometimes-fatal cardiovascular events and dangerous skin side 

effects. 

In re: Cordis IVC Filter Cases – JCCP No. 4977 Superior Court for the State of California –

OnderLaw, LLC is presently represented on the Plaintiff’s Steering Committee for litigation 

involving IVC filters, which have been linked to blood clots as well as tissue and organ 

perforation. 

Window Covering Litigation – A child dies every two weeks from strangulation on blind cords. 

OnderLaw, LLC continues to represent families in wrongful death and injury cases arising out of 

such strangulations in more than 30 states, including Missouri, Ohio, Florida, California, New 

Jersey, Illinois, Connecticut, Virginia, Maryland, Georgia, Alabama, Kentucky, Arkansas, North 

Carolina, Maine, Michigan, Indiana, Wisconsin, Minnesota, Iowa, Texas, Colorado, Arizona, 

Montana, Oregon, Washington, and Utah. This litigation has resulted in industry-wide changes 

that have saved countless lives. 

Other Pharmaceutical Litigation – OnderLaw, LLC has served in various capacities in multiple 

large-scale litigations involving pharmaceutical products or medical devices, including 

Risperdal, Invokana, Lipitor, testosterone, Fleet Phospho-Soda, Digitek, hormone replacement 

therapy (HRT), transvaginal mesh, hernia mesh, Zimmer knees, DePuy hip implants, 

Hydroxycut, Levaquin, Avandia, and breast implants. 

Class Actions – OnderLaw, LLC has led dozens of notable large-scale class action and multidistrict litigations, including dozens of consumer protection class action lawsuits nationwide 

relating to repossession and sale of vehicles. The firm’s attorneys have recovered well over $1 

billion to date in those cases. 

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6

Awards and Commendations 

OnderLaw attorneys’ commendations and awards include and are not limited to the following:

Ͳ Martindale Hubbell AV Preeminent Rating of Excellence, Top 5% of Lawyers in 

Missouri 

Ͳ Multi-Million Advocates Forum (limited to top 1% of lawyers with multi-million-dollar 

verdicts) 

Ͳ American Society of Legal Advocates – Top 1.5% of Lawyers Nationwide 

Ͳ National Trial Lawyers – Top 100 Trial Lawyers 

Ͳ America’s Top 100 High-Stakes Litigators 

Ͳ Lawyers of Distinction – 5-Star Rating 

Ͳ Top 50 Verdicts in the United States, 2016 

Ͳ 9-Figure Litigators – America’s Premier High-Stakes Lawyers 

Ͳ American Institute of Personal Injury Attorneys – 10 Best Attorneys 

Ͳ American Society of Legal Advocates – Top 100 Litigation Lawyer 

Ͳ Missouri Lawyers Weekly – Most Influential Lawyers Award 

Ͳ Missouri Lawyers Weekly – Top 3 verdicts 2016 

Ͳ Missouri Lawyers Weekly – Second largest verdict 2017 

Ͳ Rue Ratings – Best Attorneys in America 

Ͳ America’s Top 100 Litigations – Lifetime Achievement Award 

Ͳ American Association for Justice – Leaders’ Forum 

Ͳ Missouri Association of Trial Attorneys Board of Governors 

Ͳ America’s Most Honored Professionals – Top 1% 

Ͳ Kansas City Magazine’s – Top Product Liability Lawyer 

Ͳ SuperLawyers – Top 5% of Missouri Lawyers 

Ͳ AVVO Superb Score 10 of 10 

Ͳ Thompson Reuters Super Lawyers Designation 

Ͳ Public Justice Trial Lawyer of the Year Finalist 

Ͳ American Bar Association Toxic Tort & Environmental Law Vice-Chair 

Ͳ California Lawyer Attorney of the Year 

Ͳ The Nation’s Top One Percent 

Ͳ National Association of Distinguished Counsel 

Ͳ Southern California Super Lawyers 

Ͳ Top 50 Women Southern California 

Ͳ The Bar Register of Preeminent Lawyers 

Ͳ The Bar Register of Preeminent Women Lawyers 

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Exhibit 

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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

Lawana Wichmann (P) X 2.20 0.00 2.20 $747

Lawana Wichmann (P) X 10.70 0.00 10.70 $759Name (A) 0.00 0.00 0.00 $0.0

Name (A) 0.00 0.00 0.00 $0.0

Name (A) 0.00 0.00 0.00 $0.0

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

SUB-TOTAL 0.00 0.00 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 12.90 0.00 12.90 

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

Kathy Griffin (SPL) X 0.60 0.00 0.60 $203

Kathy Griffin (SPL) X 0.60 0.00 0.60 $206Name (LC) 0.00 0.00 0.00 $0.0

Name (SPL) 0.00 0.00 0.00 $0.0Name (SPL) 0.00 0.00 0.00 $0.0Name (SPL) 0.00 0.00 0.00 $0.0Name (PL) 0.00 0.00 0.00 $0.0Name (PL) 0.00 0.00 0.00 $0.0Name (PL) 0.00 0.00 0.00 $0.0Name (PL) 0.00 0.00 0.00 $0.0

0.00 0.00 0.00 $0.00.00 0.00 0.00 $0.0

SUB-TOTAL 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 1.20 0.00 1.20 GRAND TOTAL: 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 14.10 0.00 14.10 

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

OnderLaw, LLC Reporting Period: Inception through February 28, 2022

 556281 

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Exhibit 

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CATEGORY DESCRIPTION 

(If necessary) CUMULATIVE COSTS

Litigation Assessment

Court Costs - Filing Fees $400.00

Experts/consultants

Federal Express / UPS /Ontrac

Postage / U.S. Mail

Service of Process $280.00

Messenger/delivery

Hearing Transcripts

Investigation

Lexis/westlaw $25.06

Photocopies - in House

Photocopies - Outside

Telephone/telecopier

Travel - Transportation

(Airplanes - Coach Fares Only)

Travel - Meals

($75 per person / day cap)

Travel - Hotels

Miscellaneous

TOTAL EXPENSES $705.06

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

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