One of the World’s Largest Quick Service Restaurant Chains



Investigation and Preparation of Declaratory Evidence for Class Action Certification Proceedings



A Quick Service Restaurant Chain with more than 5,000 locations in the U.S. and 250 internationally was in the process of responding to a massive wage and hour class action lawsuit affecting approximately 200 company-owned restaurants in California.

As part of the litigation process, the Client needed to collect 100 witness declarations from hourly non-exempt employees. The Client wanted seasoned attorneys to conduct the interviews, because the responses could reveal issues that could help or hurt the Client’s case as well as aid in preparation for future defense strategy.

Recognizing the need to control the process and costs of the litigation, the Client sought to reduce its dependence solely on outside counsel. The Client called on RGP Legal for assistance.


How We Helped

RGP Legal worked collaboratively with the Client and its outside counsel to understand the allegations in the wage and hour complaint. A team of five RGP Legal attorneys was strategically deployed to various store locations throughout California to conduct in-depth witness interviews. Due to the largely Spanish-speaking employee base, each was assigned a translator. Upon completion of each interview, the consultants drafted declarations to be signed by the employee and then partnered with the Client and outside counsel to determine the merit and relevancy of such evidence. To the extent that any practical Human Resources matters were spotted, the consultants flagged the issues for the Client and outside counsel.



The Client reported a significant, six-figure cost savings by following this multi-sourcing approach. In addition, the Client reported that they were able to use over 95% of the declarations in the class certification hearing.