MADISON LAIRD, individually, and on behalf of all others similarly situated v. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

Opinion

111 Kane Moon (SBN 249834) Allen Feghali (SBN 301080) 222 Jacquelyne VanEmmerik (SBN 339338) 725 South Figueroa Street, 31st Floor 444 Los Angeles, CA 90017 555 Telephone: (213) 232-3128 Facsimile: (213) 232-3125 666 Email: kmoon@moonlawgroup.com 777 Email: afeghali@moonlawgroup.com Email: jvanemmerik@moonlawgroup.com 888 999 Attorneys for Plaintiff MADISON LAIRD 111000 UNITED STATES DISTRICT COURT 111111 FOR THE NORTHERN DISTRICT OF CALIFORNIA 111222 111333 MADISON LAIRD, individually, and Case No.: 3:23-cv-04237-CRB 111444 on behalf of all others similarly situated, [Assigned to Hon. Charles R. Breyer, 111555 Courtroom 6] Plaintiff, 111666 vs. [PROPOSED] ORDER: 111777 AVANADE INC, a Washington 1. CERTIFYING SETTLEMENT 111888 corporation; and DOES 1 through 10, CLASS; inclusive, 2. FINALLY APPROVING 111999 Defendants. PROPOSED SETTLEMENT; 222000 3. AWARDING FEES AND COSTS TO CLASS COUNSEL; 222111 4. AWARDING SERVICE PAYMENT 222222 TO PLAINTIFF; AND 5. DIRECTING ENTRY OF 222333 JUDGMENT 222444 Date: July 10, 2026 222555 Time: 10:00 a.m. Courtroom: 6 222666 222777 Complaint filed: June 28, 2023 Trial date: Not set 222888 111 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 222 Plaintiff MADISON LAIRD (“Plaintiff”) and Defendant Avanade Inc. 333 (“Defendant”) (Plaintiff and Defendant together, “the Parties”) have reached a class action 444 settlement involving claims asserted under the Fair Credit Reporting Act and related state 555 law statutes. 666 Plaintiff has filed a motion for final approval of a class action settlement of the 777 claims asserted against Defendant in this action, memorialized in the Joint Stipulation of 888 Class Action Settlement (the “Settlement”) (see, Declaration of Kane Moon in Support of 999 Plaintiff’s Motions for (1) Final Approval of Class Action Settlement and (2) Award for 111000 Attorneys’ Fees and Costs, and Service Payment to Plaintiff [“Moon Decl.”], Ex. 1) with 111111 attached Exhibits. In addition, Plaintiff concurrently filed a motion for an award of fees, 111222 costs, and class representative service payment, which was considered in conjunction with 111333 the motion for final approval. 111444 The Settlement between the Parties provides that the Parties stipulate to certification 111555 of a Class for settlement purposes only. The Settlement is conditioned upon, among other 111666 things, the Court’s approval. Capitalized terms in this Order shall have the same meaning 111777 as in the Settlement unless indicated otherwise. A summary of the terms of the Settlement 111888 is as follows: 111999 • The Parties stipulate to Class certification for purposes of settling the Action 222000 only. (Settlement, ¶ 12.2.) 222111 • The Class is: All current and former employees of Defendant who were hired in 222222 the United States at any time during the period from June 18, 2018, through 222333 April 27, 2025 (the “Class Period”). (Id. at ¶¶ 1.4, 1.12.) Excluded from the 222444 Settlement Class are all persons who properly and timely elect to opt out. (Id. at 222555 ¶ 1.25.) 222666 • Defendant will pay $300,000.00 as the Gross Settlement Amount. (Id. at ¶ 222777 3.0.) 222888 111 • The Settlement is a non-reversionary settlement. (Id. at ¶ 3.0.) 222 • Each Participating Class Member will receive an equal share of the Net 333 Settlement Amount. (Id. at ¶ 1.23.) 444 • For any Class Member whose Individual Class Payment check is uncashed 555 and cancelled after 180 days from date of mailing (the “void date”), or for any 666 Class Member whose envelope is returned and no forwarding address can be 777 located for the Class member after reasonable efforts have been made, the 888 Administrator shall transmit the funds represented by such checks to the 999 California Controller’s Unclaimed Property Fund in the name of the Class 111000 Member, thereby leaving no unpaid residue. (Id. at ¶¶ 4.1.1-4.13.) 111111 After reviewing the Settlement and other related documents, and having heard the 111222 argument of Counsel for respective Parties, if any, IT IS HEREBY ORDERED AS 111333 FOLLOWS: 111444 1. The Court finds that the proposed class satisfies the requirements of a 111555 settlement class under Rule 23 of the Federal Rules of Civil Procedure. For purposes of 111666 settlement, the requirements of Rule 23(a) are satisfied because the proposed Class is so 111777 numerous that joinder of all Class Members is impracticable, there are questions of law 111888 or fact common to the Class, the claims of Plaintiff are typical of the claims of the 111999 Class; and Plaintiff will fairly and adequately protect the interests of the Class. The 222000 requirements of Rule 23(b) are satisfied because questions of law or fact common to 222111 Class Members predominate over any questions affecting only individual Class 222222 Members. 222333 2. The Parties’ settlement appears to have been made and entered into in 222444 good faith and is hereby finally approved as fair, adequate, and reasonable, subject to 222555 the limitations on the requested fees and payments as set forth below. 222666 3. The following persons are certified as Class Members solely for the 222777 purpose of entering a settlement in this matter: 222888 All current and former employees of Defendant who were hired in the 111 United States at any time during the period from June 18, 2018, through 222 April 27, 2025. 333 Participating Class Members are those who did not submit a valid and timely Request for 444 Exclusion. Based on the Declaration of Nathalie Hernandez on behalf of ILYM Group, 555 Inc. (“ILYM”), 7 Class Members submitted a valid and timely Request for Exclusion 666 pursuant to the Settlement. Accordingly, these 7 individuals are excluded from the Class, 777 and there remains 4,716 Participating Class Members. 888 4. The distribution of the Class Notice directed to the Class Members as set 999 forth in the Settlement and the Court’s directions has been completed in conformity 111000 with the Preliminary Approval Order. The Class Notice provided due and adequate 111111 notice of the proceedings and of the matters set forth therein, including the proposed 111222 settlement terms as set forth in the Settlement, to all persons entitled to such Notice. 111333 The Class Notice fully satisfied the requirements of due process, having been sent to all 111444 Class Members who could be identified through reasonable effort, and was the best 111555 notice practicable under the circumstances. The Class Notice fully and accurately 111666 informed Class Members of all material elements of the proposed settlement and their 111777 opportunity to exclude themselves from, or object to, the Settlement. 111888 5. By filing the motion for an award of attorneys’ fees, costs, and service 111999 payment award, and by also permitting Class Members to object to those amounts 222000 through the hearing of the motion for final approval, Plaintiff has satisfied the notice 222111 and opportunity to respond requirements of In re Mercury Interactive, 816 F.3d 988 222222 (9th Cir. 2010). 222333 6. Plaintiff is confirmed as the Class Representative for settlement purposes. 222444 Moon Law Group, PC is confirmed as Class Counsel. 222555 7. ILYM is confirmed as the Settlement Administrator, pursuant to the terms 222666 set forth in the Settlement. The Court hereby directs payment to the Administrator for 222777 fees and expenses, in the amount of $20,550.00 to be paid pursuant to the Settlement’s 222888 terms for such distribution. The Court finds that the Settlement Administrator has thus 111 far fully discharged its obligations as Settlement Administrator under the terms of the 222 Settlement, and the Settlement Administrator is directed to complete the administration 333 as set forth in the Settlement. 444 8. The Court hereby awards Class Counsel, Moon Law Group, PC 555 $76,594.86 in attorney’s fees, equal to 30% of the net settlement amount, and 666 $19,133.80 in costs. 777 9. The Court hereby awards Class Representative Service Payment of 888 $5,000.00 to Plaintiff, to be paid in accordance with the terms of the Settlement. The 999 Court finds that this amount is fair and reasonable in light of Plaintiff’s services in 111000 support of the Action and executing a general release. 111111 10. The Court directs payment to all Class Members pursuant to the terms of 111222 the Settlement. 111333 11. The Court orders that a Qualified Settlement Fund, as defined in US Treasury 111444 Regulation § 468B-1, or other applicable law, shall be established to effectuate the terms 111555 of the Settlement and the orders of the Court. 111666 12. Defendant shall pay a total of $300,000.00 to resolve this litigation. 111777 Defendant will fund the Gross Settlement Amount by transmitting such funds to the 111888 Administrator within 30 calendar days of the Effective Date.1 111999 13. Class Members were given a full opportunity to participate in the Final 222000 Approval Hearing, and all Class Members and other persons wishing to be heard have 222111 been heard. As of the date of this Order and Judgment, no Class Member has objected to 222222 the Settlement. Participating Class Members who did not timely object to the settlement 222333 set forth in the Settlement are barred from prosecuting or pursuing any appeal of the Final 222444 222555 1 “Effective Date” means the date on which the Court’s Final Approval Order and entry of Judgment become Final. (Settlement, ¶ 1.18.) “Final” shall mean the latest of: (i) if there is an appeal of the 222666 judgment, the date the Final Approval Order and Judgment are affirmed on appeal, the date of dismissal of such appeal, or the expiration of the time to file a petition for writ of certiorari; (ii) if a petition for writ 222777 of certiorari is filed, the date of denial of the petition for writ of certiorari, or the date the Final Approval Order and Judgment are affirmed pursuant to such petition; or (iii) if no appeal is filed, the expiration 222888 date of the time for filing or noticing any appeal of the Final Approval Order and Judgment. (Id.) 111 Approval Order and Judgment. 222 14. Effective on the date Defendant fully funds the entire Gross Settlement 333 Amount, Plaintiff and Participating Class Members will release claims against all 444 Released Parties as follows: 555 a. Released Parties. “Released Parties” means Defendant and Accenture 666 LLP, and all of their former, present or future parents, subsidiaries, 777 and/or affiliates; each of the foregoing’s present, former, or future 888 owners, directors, officers, shareholders, partners, managing agents, 999 employees, insurers, successors, predecessors, contractors, members, 111000 stockholders, representatives, benefit plan fiduciaries, and assigns; any 111111 and all agents, legal representatives, and/or attorneys of all of the 111222 foregoing entities or individuals; and any entities or individuals alleged 111333 to be joint employers with Avanade Inc. and/or Accenture LLP. 111444 b. Plaintiff’s Release. Other than described in section 5.0.1 of the 111555 Settlement, Plaintiff fully and finally releases and discharges the 111666 Released Parties from any and all charges, complaints, claims, and 111777 liabilities of any kind or nature whatsoever, known or unknown, 111888 suspected or unsuspected (“claim(s)”) which Plaintiff at any time 111999 heretofore had or claimed to have or which Plaintiff may have or shall in 222000 the future claim to have, including, without limitation, any and all claims 222111 related or in any manner incidental to Plaintiff’s employment with 222222 Defendant. Plaintiff understands that he is releasing potentially unknown 222333 claims, and that Plaintiff may have limited knowledge with respect to 222444 some of the claims being released. Plaintiff acknowledges that there is a 222555 risk that, after signing this Agreement, Plaintiff may learn information 222666 that might have affected Plaintiff’s decision to enter into this Agreement. 222777 Plaintiff assumes this risk and all other risks of any mistake in entering 222888 into this Agreement. Plaintiff agrees that this Agreement is fairly and 111 knowingly made. Plaintiff represents and warrants that Plaintiff has all 222 necessary authority to enter into this Agreement (including, if Plaintiff is 333 married, on behalf of Plaintiff’s marital community) and that Plaintiff 444 has not transferred any interest in any claims to any spouse or to any 555 other third party. The Parties understand the word “claim(s)” to include 666 all actions, complaints, claims, and grievances, whether actual or 777 potential, known or unknown, and specifically but not exclusively, all 888 claims arising out of Plaintiff’s employment with Defendant including, 999 but not limited to, any and all claims under the Fair Employment and 111000 Housing Act, Age Discrimination in Employment Act, Americans with 111111 Disabilities Act, and Title VII of the Civil Rights Act of 1964. This will 111222 also include a release of any and all claims, known or unknown, 111333 contingent or accrued arising out of any act or event that occurred prior 111444 to execution of the release, including a California Civil Code section 111555 1542 waiver (collectively, “Plaintiff’s Released Claims”). 111666 c. Release by Participating Class Members. All Participating Class 111777 Members, including Plaintiff, fully and finally release and discharge the 111888 Released Parties from any and all claims which were or could have been 111999 asserted against the Released Parties based upon, arising out of, or 222000 relating to the facts or allegations set forth in any complaint in the 222111 Action (including any subsequently amended complaints), including but 222222 not limited to claims for violations of background check requirements; 222333 violations of background check notice requirements; violations of 222444 background check authorization requirements; violations of consumer 222555 report requirements; violations of investigative consumer report 222666 requirements; violations of credit check requirements; unfair business 222777 practices; willful violations for any or all of the foregoing; restitution for 222888 any or all of the foregoing; any penalties, including statutory and civil 111 penalties, related to any or all of the foregoing; attorneys’ fees or costs 222 related to any or all of the foregoing; interest related to any or all of the 333 foregoing; and/or any other damages or amounts related to any or all of 444 the foregoing. This release includes, but is not limited to, claims 555 pursuant to the Fair Credit Reporting Act (15 U.S.C. §§ 1681, et seq.), 666 the California Investigative Consumer Reporting Agencies Act 777 (California Civil Code §§ 1786 et seq.), and California Business & 888 Professions Code §§ 17200 et seq. (collectively, the “Released Class 999 Claims”). 111000 15. The Court directs that the Clerk of the Court enter the Court’s Order as a 111111 Final Judgment. Plaintiff and Class Members shall take nothing from Defendant except as 111222 set forth in the Settlement and this Final Approval Order and Judgment. 111333 16. Neither this Order, the Settlement, nor any related statements or proceedings 111444 shall be construed or deemed an admission of liability, culpability, damage or wrongdoing 111555 on the part of Defendant, or of the appropriateness of certification of the Class other than 111666 for settlement purposes. 111777 17. In the event the Judgment is overturned, reversed, not affirmed in its entirety, 111888 or never becomes final, the Effective Date does not occur, or the Settlement is nullified or 111999 modified for any reason, Defendant does not waive any and all rights, including its right to 222000 oppose class certification. The Settlement is a settlement document and shall be 222111 inadmissible in evidence in any proceeding, except an action or proceeding to approve, 222222 interpret, or enforce the Settlement. 222333 18. The Court orders that, without affecting the finality of the Final Approval 222444 Order and Judgment, it reserves continuing jurisdiction over the parties for the purposes of 222555 implementing, enforcing and/or administering the Settlement or enforcing the terms of the 222666 Judgment. 222777 19. Plaintiff’s Motion for Final Approval of Class Action Settlement and 222888 Plaintiff’s Motion for an Award of Attorneys’ Fees and Costs, and Service Payment to 1 Plaintiff are hereby granted, and the Court directs that Judgment shall be entered in 2 accordance with the terms of this Order. 3 20. The Court sets a Non-Appearance Hearing (Case Review) Re: Distribution 4} on May 14 , 2027 at 10:00am. by Zoom. Class Counsel 1s ordered to file 5 a final report and declaration regarding distribution no later than 6 April 28, 2027 . 8 9 Dated: July 16, 2026 xo K Yo Honorable Charles R. Breyer 10 Judge of the Northern District of California 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28