Johnson et al v. Hewlett-Packard Company

Filing 321

ORDER by Judge Charles R. Breyer denying 317 Motion for Leave to File a Motion for Reconsideration; granting in part and denying in part 284 Motion for Attorney Fees and Costs. (crblc2, COURT STAFF) (Filed on 7/24/2014).

Download PDF
1 2 IN THE UNITED STATES DISTRICT COURT 3 FOR THE NORTHERN DISTRICT OF CALIFORNIA 4 5 No. C 09-03596 CRB JEFFREY JOHNSON, et al., 6 Plaintiffs, 7 v. 8 HEWLETT-PACKARD COMPANY, 9 Defendant. / ORDER RE PLAINTIFFS’ MOTION FOR LEAVE TO FILE A MOTION FOR RECONSIDERATION, DEFENDANT’S MOTION FOR ATTORNEYS’ FEES, AND DEFENDANT’S REQUEST FOR COSTS United States District Court For the Northern District of California 10 Plaintiffs Jeffrey Johnson, Jennifer Riese, Shaun Simmons, and James Purvis brought 11 12 suit against Hewlett-Packard, claiming breach of employment contract, unjust enrichment, 13 promissory estoppel, and violations of California Labor Code and wage orders, the California 14 Unfair Business Practices Act, and the Colorado Wage Claim Act. The Court granted 15 Defendant’s motions for summary judgment against all Plaintiffs and denied Plaintiffs’ 16 Motion to File a Fourth Amended Complaint. Before the Court is Plaintiffs’ Motion for 17 Leave to File a Motion for Reconsideration of this Court’s prior order regarding California 18 Labor Code section 218.5. Also before the Court is Defendant’s Request for Costs and 19 Amended Motion for Attorneys’ Fees. The Court (1) DENIES Plaintiffs’ Motion for Leave 20 to File a Motion for Reconsideration; (2) DENIES Defendant’s Motion for Attorneys’ fees as 21 to Plaintiffs Johnson, Riese, and Simmons; (3) GRANTS in part Defendant’s Motion for 22 Attorneys’ fees as to Plaintiff Purvis; (4) DENIES the award of attorneys’ fees against 23 Plaintiffs’ counsel; and (5) GRANTS in part Defendant’s Request for Costs. 24 I. 25 PROCEDURAL HISTORY Plaintiffs Jeffrey Johnson, Jennifer Riese, Shaun Simmons, and James Purvis 26 (collectively, “Plaintiffs”) brought this class action for unpaid bonuses and commissions 27 (together, “wages”) against their former employer, Hewlett-Packard Company (“HP” or 28 “Defendant”). Originally, only Johnson, Riese, and Simmons, who are all residents of Colorado (hereinafter “Colorado Plaintiffs”), were named plaintiffs in the suit. See First Am. 1 Compl. (“FAC”) (dkt. 8) ¶¶ 4-6. The Colorado Plaintiffs alleged five causes of action 2 including (1) breach of contract, (2) unjust enrichment, (3) promissory estoppel, (4) 3 violations of the California Labor Code, and (5) violations of the California Unfair Business 4 Practices Act, and also demanded an accounting. Id. They made no claims under Colorado 5 law. See id. 6 In January 2010, HP moved to dismiss the Colorado Plaintiffs’ claims under the California Labor Code and California Business and Professions Code, arguing that those 8 claims were “predicated on an unconstitutional application of California law to non- 9 California residents.” See Def.’s Mot. to Dismiss FAC (dkt. 20) ¶ 4. The Court denied the 10 United States District Court For the Northern District of California 7 motion and allowed the Colorado Plaintiffs to amend their complaint. Minute Entry Mar. 5, 11 2010 (dkt. 43). They amended it with claims under the Colorado wage statute but maintained 12 that California law applied to non-California employees. See Second Am. Compl. (“SAC”) 13 (dkt. 44) ¶¶ 94, 139-52. 14 In May 2010, HP moved to strike the Colorado Plaintiffs’ California claims from the 15 SAC, arguing that “[n]on-California Plaintiffs have no right to sue for violation of California 16 law and such representation would result in an unconstitutional application of California law 17 to non-California residents.” See Def.’s Am. Mot. to Strike (dkt. 52) ¶ 1. Finding “no 18 authority for the proposition that workers who never set foot in California are protected by 19 California employment law,” the Court granted HP’s motion to strike those claims as to the 20 non-California employees. Order on Mot. to Strike (dkt. 62) at 7-8. The Court instructed the 21 Colorado Plaintiffs to amend their complaint, clarifying “that only those employees who 22 worked for some period in California are suing under California employment law.” Id. at 2- 23 3. Plaintiffs filed a Third Amended Complaint (“TAC”)—the operative complaint—adding 24 California Plaintiff James Purvis to represent the putative subclass of California employees 25 and indicating that only Purvis and HP’s California employees would pursue claims under 26 California law. See TAC (dkt. 69) ¶¶ 8, 94. 27 28 In February 2011, HP filed a separate motion for summary judgment directed at each of the named Plaintiffs and all of their claims. Mot. for Summ. J. re Johnson (dkt. 147); Mot. 2 for Summ. J. re Riese (dkt. 140); Mot. for Summ. J. re Simmons (dkt. 153); Mot. for Summ. 2 J. re Purvis (dkt. 148). HP argued, inter alia, that none of the Plaintiffs had any evidence that 3 they actually earned specific bonuses and commissions that were never paid. See Mem. P. & 4 A. re Johnson Summ. J. (dkt. 151) at 7-8, 10-16, 20-23; Mem. P. & A. re Riese Summ. J. 5 (dkt. 141) at 9-10, 13-18, 22-25; Mem. P. & A. re Simmons Summ. J. (dkt. 150) at 8-10, 12- 6 17, 21-24; Mem. P. & A. re Purvis Summ. J. (dkt. 160), Ex. A. at 8-17, 21-24. Plaintiffs 7 filed oppositions for Purvis and the Colorado Plaintiffs. Dkt. 191. In opposition, Plaintiffs 8 relied heavily on evidence of general problems with HP’s Omega pay system. See Order 9 Granting Summ. J. (dkt. 240) at 17. Notwithstanding the evidence that HP’s Omega software 10 United States District Court For the Northern District of California 1 tool was deeply flawed, the Court ruled that none of the Plaintiffs had linked “HP’s problems 11 with actual failure to pay them what they were owed under the sales contracts.” Id. The 12 Court granted all four summary judgment motions in their entirety. Id. at 34. 13 Plaintiffs filed a notice of appeal from the judgment on August 26, 2011. Dkt. 247. 14 The Ninth Circuit affirmed this Court’s rulings on September 5, 2013. USCA Mem. (dkt. 15 271). Plaintiffs petitioned for panel and en banc rehearing, and the Ninth Circuit denied the 16 petition on October 25, 2013. See USCA Order (dkt. 275). 17 While Plaintiffs’ appeal was pending, HP filed a bill of costs (dkt. 251) and a motion 18 for attorneys’ fees (dkt. 260). After deferring briefing pending the appeal, the Court granted 19 HP’s motion to resume briefing on fees and costs and instructed HP to file an amended 20 motion for fees. See Order Deferring Briefing (dkt. 265); Order Resuming Briefing (dkt. 21 282). HP filed the pending motion for fees on December 6, 2013. Am. Mot. for Attorneys’ 22 Fees (dkt. 284). 23 24 II. PLAINTIFF’S MOTION FOR LEAVE TO FILE A MOTION FOR RECONSIDERATION 25 HP moved for attorneys’ fees pursuant to California Labor Code section 218.5.1 Am. 26 Mot. for Attorneys’ Fees. In 2013, the California legislature amended section 218.5, 27 28 1 Except where otherwise noted, henceforth all statutory references are to the California Labor Code. 3 1 effective January 1, 2014. See Cal. Lab. Code § 218.5 (2014). On March 10, 2014, the 2 Court ruled that the amended version of section 218.5 is not retroactively applicable to HP’s 3 Motion for Attorneys’ Fees. Order re Am. Section 218.5 (dkt. 309). On May 6, 2014, 4 Plaintiffs filed their pending Motion for Leave to File a Motion for Reconsideration of that 5 ruling. Mot. for Leave (dkt. 317). On July 8, 2014, the Ninth Circuit issued an order awarding HP attorneys fees on 6 7 appeal, pursuant to section 218.5. COA Fees Order (appellate dkt. 81). The Ninth Circuit 8 ruled that the amended version of section 218.5 is not retroactively applicable to this case. 9 Id. Consistent with the Ninth Circuit’s ruling, the Court DENIES Plaintiffs’ Motion for United States District Court For the Northern District of California 10 Leave to File a Motion for Reconsideration. 11 III. DEFENDANT’S MOTION FOR ATTORNEYS’ FEES 12 A. Legal Standard 13 A federal court sitting in diversity applies the law of the forum state to a motion for 14 attorneys’ fees. Kona Enters., Inc. v. Estate of Bishop, 229 F.3d 877, 883 (9th Cir. 2000). 15 Likewise, a federal court sitting in diversity applies the conflict-of-law principles of the 16 forum state. S.A. Empresa De Viacao Aerea Rio Grandense v. Boeing Co. (“Boeing”), 641 17 F.2d 746, 749 (9th Cir. 1981); see also Cutler v. Bank of Am. Nat’l Trust & Sav. Ass’n, 441 18 F. Supp. 863, 865 (N.D. Cal. 1977) (“Where the forum state would look to another state’s 19 law on that issue, the federal court must do likewise.”). Furthermore, “[a] separate choice of 20 law inquiry must be made with respect to each issue in a case.” Boeing, 641 F.2d at 749. 21 California law allows a party to recover attorneys’ fees only when provided for by 22 contract or statute. Cal. Code Civ. Proc. §§ 1021, 1033.5(a)(10). Under California Labor 23 Code section 218.5,2 attorneys’ fees “shall” be awarded to the prevailing party in “any action 24 brought for the nonpayment of wages.” Cal. Lab. Code § 218.5; see also Earley v. Super. 25 Ct., 79 Cal. App. 4th 1420, 1427 (2000) (“Section 218.5 entitles the prevailing party, in any 26 action for ‘wages,’ to a mandatory award of costs and attorney’s fees.”). 27 2 28 Henceforth, all references to section 218.5 will be to the pre-amendment version, consistent with this Court’s March 10, 2014 order . See Cal. Lab. Code § 218.5 (1986); Order re Am. Section 218.5. 4 1 B. 2 3 HP’s Motion for Attorneys’ Fees Is Granted in Part As to James Purvis, but Denied As to the Colorado Plaintiffs As the prevailing party, HP moves the Court to award $159,634.38 in attorneys’ fees 4 under section 218.5.3 Am. Mot. for Attorneys’ Fees at 23; Brafford Decl. (dkt. 284-1), Ex. 5 C. Although HP seeks fees only for work related to defending Purvis’s California claims, HP 6 asks the Court to enter the fees award against all four Plaintiffs. See Am. Mot. for 7 Attorneys’ Fees at 8, 17; Brafford Decl. ¶ 19. Plaintiffs do not contest that section 218.5 8 authorizes an award of fees against Purvis. See generally id. 9 Using the Lodestar method, HP requests $159,634.38 in fees. Am. Mot. for United States District Court For the Northern District of California 10 Attorneys’ Fees at 23. “[A] court assessing attorney fees begins with a touchstone or 11 lodestar figure, based on the ‘careful compilation of the time spent and reasonable hourly 12 compensation of each attorney . . . involved in the presentation of the case.” Ketchum v. 13 Moses, 24 Cal. 4th 1122, 1131-32 (2001). Although the lodestar figure is presumptively 14 reasonable, see Morales v. City of San Rafael, 96 F.3d 359, 363 n.8 (9th Cir. 1996), the 15 Court is “not bound by the amount sought by defendants and ha[s] discretion to award them a 16 lesser sum.” Robertson v. Rodriguez, 36 Cal. App. 4th 347, 362 (1995); see also Thayer v. 17 Wells Fargo Bank, N.A., 92 Cal. App. 4th 819, 834 (2001) (“There is no hard-and-fast rule 18 limiting the factors that may justify an exercise of judicial discretion to increase or decrease a 19 lodestar calculation.”). 20 Plaintiffs do not dispute the reasonableness of the billing rates, but object that (1) 21 HP’s record-keeping is deficient and contains “block billing,” and (2) the hours billed are 22 excessive and duplicative. See Response. First, Plaintiffs object that “HP has not made any 23 effort to demonstrate how many of the entries were directly related solely to the California 24 Labor Claims of James Purvis.” See id. at 28. However, HP need only demonstrate that the 25 entries relate to Purvis’s claims for unpaid wages under any legal theory. See Lutz v. 26 27 28 3 A party can move for fees under section 218.5 if they are (1) the prevailing party in (2) a wage claim, and (3) at least one party “request[ed] attorneys’ fees and costs upon initiation of the action.” Cal. Lab. Code § 218.5. Plaintiffs’ complaints and HP’s answer requested fees, satisfying this final requirement of section 218.5. See FAC; SAC; TAC; Answer to TAC (dkt. 71). 5 1 Sortwell, 2011 WL 3241626, at *9 (Cal. Ct. App. July 29, 2011) (section 218.5 is a source of 2 fees for unpaid wage claim under partnership theory). HP has already attempted to separate 3 entries pertaining to Purvis from those pertaining to the Colorado Plaintiffs. See Brafford 4 Decl., Ex. A. 5 Plaintiffs next argue that HP’s records are insufficient because of “block billing,” or billing for multiple tasks in a single entry and masking the time spent on specific tasks. 7 Response at 25, 27-28. HP has chosen to account for the “block billing” by reducing those 8 entries to a fraction that represents only work connected to Purvis’s claims. Brafford Decl. 9 ¶ 23. Given HP’s success in this Court and on appeal, HP’s billings are presumptively 10 United States District Court For the Northern District of California 6 reasonable, and so the “block billing” is less problematic where HP has clearly made an 11 effort to apportion its block entries. See Hensley v. Eckerhard, 461 U.S. 424, 435 (1983) 12 (degree of success is critical in determining reasonable fee and attorneys are normally 13 compensated for all hours reasonably expended). The Court finds that HP’s record-keeping 14 is sufficient to support its motion. 15 Plaintiffs also argue that HP’s time entries suggest excessive and duplicative work. 16 Response at 24-27. HP requests fees for 488.94 hours billed by eighteen attorneys and three 17 paralegals for defending Purvis’s claims. See Brafford Decl., Exs. A, C. After evaluating 18 the specific entries that Plaintiffs challenge, the Court finds that the below categories of work 19 are duplicative or excessive. The Court reduces HP’s award from $159,634.38 as requested 20 to $79,315.85. The Court arrives at this reduced figure after deducting $80,318.53 for 21 excessive hours in the following categories: • Eight attorneys and one paralegal collectively billed over 36 hours to prepare HP’s answer to the TAC and nearly 9 hours for HP’s amended answer. The charges for this work totaled $16,989.02. See Brafford Decl., Exs. A, C. Finding the number of individuals involved to be excessive and duplicative, the Court reduces this group of billings and awards $5,850. • Three attorneys and two paralegals billed at least 104.6 hours and $28,150.50 solely in preparing for the deposition of James Purvis. See Brafford Decl., Exs. A, C. Finding the hours spent to be excessive and duplicative, the Court reduces this group of billings and awards $9,000. • 22 Two attorneys billed a total of 17.7 hours and $9,544.50 to take James Purvis’s deposition. See Brafford Decl., Exs. A, C. Finding the hours spent to be 23 24 25 26 27 28 6 excessive and duplicative, the Court reduces this group of billings and awards $2,607.00. 1 2 • One attorney billed 3.2 hours and $1,024 to prepare a two-page notice of motion for summary judgment. See Brafford Decl., Exs. A, C; Notice of Summ J. Mot. (dkt. 148). The Court declines to award these fees. • 8 Eight attorneys and one paralegal collectively billed at least 208.5 hours and $78,756.01 to research and prepare the motion for summary judgment and reply against James Purvis. See Brafford Decl., Exs. A, C. This figure includes over $6,000 billed for preparing an amended summary judgment motion because HP chose to file its original motion before deposing Purvis. Id. Finding the number of individuals and hours expended to be excessive and likely inefficient, the Court reduces this group of billings and awards $36,688.50. 9 The total reductions made by the Court for these categories of work equal $80,318.53. 3 4 5 6 7 United States District Court For the Northern District of California 10 Apart from the above categories of work, HP’s hours are presumptively reasonable. See 11 Morales, 96 F.3d at 363 n.8; Hensley, 461 U.S. at 435. Accordingly, HP’s motion for fees is 12 GRANTED in part. The Court deducts $80,318.53 from HP’s request of $159,634.38 and 13 awards $79,315.85 against Purvis. 14 Had HP sought an award of fees against Colorado Plaintiffs for the work required to 15 defend against the Colorado Plaintiffs’ section 218.5 claims, HP likely would have prevailed. 16 Instead, HP specifically declined to seek fees for all work predating this Court’s Order 17 striking the Colorado Plaintiffs’ section 218.5 claims. See, e.g., Bradford Decl. Ex. A 18 (billing for fees incurred from July 22, 2010 forward, the day after Plaintiffs added Purvis in 19 the TAC, and weeks after this Court granted HP’s motion to strike the Colorado Plaintiffs’ 20 section 218.5 claims). HP would have this Court order Colorado Plaintiffs to pay the fees 21 accrued defending against Purvis’ claims. HP’s argument fails because it lacks mutuality. 22 HP wants fees awarded against the Colorado Plaintiffs only for that portion of the litigation 23 for which Colorado Plaintiffs, had they prevailed, would not have been able to recover fees 24 from HP. That is, once the Court struck the Colorado Plaintiffs’ section 218.5 claims, they 25 would have been unable to recover fees from HP under that section. Therefore, while HP 26 would have been entitled to recover fees incurred defending against the Colorado Plaintiffs’ 27 section 218.5 claims through the Motion to Strike, HP is not entitled to fees from the 28 7 1 Colorado Plaintiffs after the Order granting the Motion to Strike. The Court DENIES HP’s 2 motion as to the Colorado Plaintiffs. 3 IV. MOTION FOR ATTORNEYS’ FEES AGAINST PLAINTIFFS’ COUNSEL 4 HP moves the Court to order Plaintiffs’ counsel jointly liable for the award of 5 attorneys’ fees against Plaintiffs for engaging in “unduly aggressive litigation tactics.” Am. 6 Mot. for Attorneys’ Fees at 3. HP has also asked the Court to grant a separate award of 7 sanctions in the amount of $141,613.53 solely against Plaintiffs’ counsel. Id. at 23. A. 9 Whenever an attorney “so multiplies the proceedings in any case unreasonably and 10 United States District Court For the Northern District of California 8 Legal Standard vexatiously,” the Court may award sanctions to compensate the opposing party for excess 11 costs and fees reasonably incurred because of such conduct. 28 U.S.C. § 1927. However, 12 “[t]he strong public policy in favor of the peaceful resolution of disputes in the courts 13 requires that attorneys not be deterred from pursuing legal remedies because of a fear of 14 personal liability. To decide otherwise ‘would inject undesirable self-protective reservations 15 into the attorney’s counselling role,’ and prevent counsel from devoting their entire energies 16 to their clients’ interests.” See In Re Marriage of Flaherty, 31 Cal. 3d 637, 647 (1982). For 17 this reason, courts award sanctions sparingly. 18 B. Awarding Fees Against Plaintiffs’ Counsel is Improper 19 HP relies on Villalobos v. Guertin, 2009 WL 4718721, at *5 for the proposition that 20 Plaintiffs’ counsel should participate in the award of attorneys fees against their clients, and 21 relies on 28 U.S.C. § 1927 for its request that counsel be separately sanctioned. See Am. 22 Mot. for Attorneys’ Fees at 19-23. However, the kinds of conduct that would justify the two 23 awards are characteristically different, and HP’s motion muddles the distinction. See id. 24 This case is unlike Villalobos and the Court finds no reason to order counsel to participate in 25 the award of fees. The Court also finds insufficient grounds to separately sanction Plaintiffs’ 26 counsel. 27 28 8 2 It Would Be Improper to Order Counsel Liable for the Fees Awarded Against Plaintiffs HP argues that, in certain circumstances, fees awarded under section 218.5 may be 3 awarded against counsel. Am. Mot. for Attorneys’ Fees at 19-23 (citing Villalobos, 2009 4 WL 4718721, at *5). In Villalobos, counsel failed to identify the correct defendants in the 5 pleadings and subsequently failed to timely amend, resulting in dismissal of plaintiff’s 6 claims. 2009 WL 4718721, at *5. In light of counsel’s failure to attentively prosecute the 7 case, the court concluded that “equity demands that the award be paid by plaintiff’s counsel.” 8 Id. Villalobos is a poor fit for this case. Here, HP’s chief complaint that Plaintiffs used 9 “unduly aggressive litigation tactics” is essentially the opposite of the situation presented in 1 1. United States District Court For the Northern District of California 10 Villalobos. See Am. Mot. For Attorneys’ Fees at 3. Counsel’s prosecution of this case 11 shares no resemblance to the ineptitude in Villalobos, and it is more appropriate to scrutinize 12 Plaintiffs’ allegedly “aggressive litigation tactics” under a motion for sanctions. 13 Accordingly, the Court adheres to the “general rule” that fee awards are to be paid by the 14 parties. See Villalobos, 2009 WL 4718721, at *5. 15 16 2. It Would Be Improper to Sanction Counsel Under 28 U.S.C. § 1927 HP also moves for sanctions and lists the following conduct to justify that award: (1) 17 counsel’s arguments in the FAC and SAC that the Colorado Plaintiffs had standing to pursue 18 claims under California law; (2) the addition of Jeffrey Kossick—a plaintiff with no 19 standing—to the SAC; (3) Plaintiffs’ challenge to Discovery Magistrate Order No. 9 relating 20 to the definition of “Omega;” and (4) Plaintiffs’ motion to amend their TAC to expand the 21 definition of “Omega.” See Brafford Decl. ¶ 20. 22 Sanctions against an attorney are an extraordinary remedy that courts should resort to 23 sparingly. See In Re Marriage of Flaherty, 31 Cal. 3d at 647. Here, Plaintiffs’ counsel 24 appears to have unnecessarily multiplied the proceedings in this litigation, but recognizing 25 the undesirable chilling effect of sanctions, the Court is unconvinced that counsel’s 26 prosecution of this case rose to a sanctionable level of misconduct. HP’s request for 27 attorneys’ fees against Plaintiffs’ counsel is DENIED. 28 9 1 V. REQUEST FOR COSTS HP moves for costs pursuant to Federal Rule of Civil Procedure 54(d)(1). Rule 2 3 54(d)(1) creates a presumption in favor of awarding costs to a prevailing party but vests in 4 the courts discretion to refuse to award costs. Ass’n of Mexican-American Educators v. 5 State of Cal. (“AMAE”) 231 F.3d 572, 592 (9th Cir. 2000); Fed. R. Civ. P. 54(d)(1). Here, 6 HP seeks $695,536 in costs. See Bill of Costs. The Court GRANTS HP’s request for costs 7 but reduces the award to $86,317.60 as follows. 8 • HP requests $603,824.40 for electronic discovery processing and hosting fees. Bill of Costs at 5. The burden is on HP to “itemize its costs with enough detail to establish they are taxable.” Petroliam Nasional Berhad v. GoDaddy.com, Inc., 2012 WL 1610979 (N.D. Ca. May 8, 2012) at*4. The invoices attached by HP are too vague for the Court to determine what charges are for allowable conversion costs and which are for unallowed processing costs. Therefore the Court declines to award these costs. • HP requests $2,894 as a deposition airfare expense for John Oliver. Bill of Costs at 4. The Court finds that this expense was unnecessary and declines to award it. • 9 HP requests $56,937.12 in Special Master fees. Bill of Costs at 5. The Court awards these fees less the $2,500 in sanctions the Special Master ordered against HP and which has yet to be paid. United States District Court For the Northern District of California 10 11 12 13 14 15 16 17 VI. CONCLUSION 18 For the foregoing reasons, the Court (1) DENIES Plaintiffs’ Motion for Leave to File 19 a Motion for Reconsideration; (2) DENIES HP’s Motion for Attorneys’ fees as to Plaintiffs 20 Johnson, Riese, and Simmons; (3) GRANTS in part HP’s Motion for Attorneys’ fees as to 21 Plaintiff Purvis, reducing the award from $159,634.38 to $79,315.85; (4) DENIES HP’s 22 Motion for Attorneys’ Fees as to Plaintiffs’ counsel; and (5) GRANTS HP’s Request for 23 Costs, reducing the award from $695,536 to $86,317.60. 24 25 IT IS SO ORDERED. 26 27 Dated: July 24, 2014 CHARLES R. BREYER UNITED STATES DISTRICT JUDGE 28 10

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?