Job Description Exhibits A-K to Siegel Declaration filed in Support of Motion for Step One Notice

DocuSign Envelope ID: C10E8734-8974-4533-9F61-922A3A99C3E7

28 U.S.C. § 1746 DECLARATION OF AMANDA WRIGHT IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from October 2011 to July 2019.

Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a Claims Examiner, AMS Claims Examiner, AMS Claims Examiner II, Absence Management Specialist, and Integrated Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I did not hold any insurance or other licenses relevant to my position. Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having any college degree or an insurance license.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of

Exhibit A-K

DocuSign Envelope ID: C10E8734-8974-4533-9F61-922A3A99C3E7

action for nearly every contingency I encountered during my employment—to perform my work in a highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: C10E8734-8974-4533-9F61-922A3A99C3E7

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 75 Claims Examination Employees in Oregon and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers, including Todd Snow, Javaun Schuster, and Tammi Kilmer, would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/13/2020

Executed on _______________________

_______________________ Amanda Wright

Exhibit A-K

DocuSign Envelope ID: B66EF492-909F-40DF-8D29-5FD63627E648

28 U.S.C. § 1746 DECLARATION OF CASSANDRA MAGDALENO IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 5/15/2016 to 4/15/18. Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a FMLA Claims Examiner, FMLA Claims Examiner II, FMLA/LOA Claims Examiner and Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I was not a college graduate and did not possess any type of specialized license relevant to my position.

Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having any college degree or an insurance license.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of

Exhibit A-K

DocuSign Envelope ID: B66EF492-909F-40DF-8D29-5FD63627E648

action for nearly every contingency I encountered during my employment—to perform my work in a highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: B66EF492-909F-40DF-8D29-5FD63627E648

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 125 Claims Examination Employees in Arizona and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/12/2020

Executed on _______________________

_______________________ Cassandra Magdaleno

Exhibit A-K

DocuSign Envelope ID: 0B901FD8-2482-4A5F-83BC-D45AA47FD1AB

28 U.S.C. § 1746 DECLARATION OF COLLETTE COKLEY IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 8/1/2016 to 1/1/19. Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a Claims Examiner, Absence Management, and AMS Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I did not hold any insurance licenses or other licenses relevant to my position. Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having any college degree or an insurance license.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of action for nearly every contingency I encountered during my employment—to perform my work in a

Exhibit A-K

DocuSign Envelope ID: 0B901FD8-2482-4A5F-83BC-D45AA47FD1AB

highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: 0B901FD8-2482-4A5F-83BC-D45AA47FD1AB

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 150 Claims Examination Employees in Arizona and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/12/2020

Executed on _______________________

_______________________ Collette Cokley

Exhibit A-K

DocuSign Envelope ID: C58F952D-FB77-45BD-B273-C020B3F3A665

28 U.S.C. § 1746 DECLARATION OF JENNIFER HASSELL IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from December 2016 to December 2018. Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a Disabiliy Claims Examiner, Long Term Disability Examiner, and Long Term Disability Specialist. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. I, however, did hold a degree in crimincal justice from Florida State University during my employment.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of action for nearly every contingency I encountered during my employment—to perform my work in a

Exhibit A-K

DocuSign Envelope ID: C58F952D-FB77-45BD-B273-C020B3F3A665

highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: C58F952D-FB77-45BD-B273-C020B3F3A665

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 50 Claims Examination Employees in Florida and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers, including Mary Floyd, would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/31/2020 Executed on _______________________

_______________________ JENNIFER HASSELL

Exhibit A-K

DocuSign Envelope ID: 144CD0E2-8456-4CDB-B6D9-FF303B0446D9

28 U.S.C. § 1746 DECLARATION OF JESSIE SANCHEZ IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 8/1/2016 to 1/15/18. Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a AMS Claims Examiner, Integrated Claims Examiner, and Absence Management Specialist. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I did not hold any insurance licenses or other licenses relevant to my position. Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having any college degree or an insurance license.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of action for nearly every contingency I encountered during my employment—to perform my work in a

Exhibit A-K

DocuSign Envelope ID: 144CD0E2-8456-4CDB-B6D9-FF303B0446D9

highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: 144CD0E2-8456-4CDB-B6D9-FF303B0446D9

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 125 Claims Examination Employees in Arizona and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/17/2020

Executed on _______________________

_______________________ JESSIE SANCHEZ

Exhibit A-K

DocuSign Envelope ID: 604BB45A-1DF2-43A1-8786-B0EF076D96DE

28 U.S.C. § 1746 DECLARATION OF KIMBERLY GREEN IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 12/29/2014 to 6/14/19.

Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a Absence Management Specialist, AMS Claims Examiner, and Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I was not a college graduate and did not possess any type of specialized license relevant to my position.

I also worked with other Claims Examination Employees who qualified for their positions despite not having any college degree or an insurance license.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of action for nearly every contingency I encountered during my employment—to perform my work in a

Exhibit A-K

DocuSign Envelope ID: 604BB45A-1DF2-43A1-8786-B0EF076D96DE

highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: 604BB45A-1DF2-43A1-8786-B0EF076D96DE

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 40 Claims Examination Employees in Oregon and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/13/2020

Executed on _______________________

_______________________ KIMBERLY GREEN

Exhibit A-K

DocuSign Envelope ID: BAFD91B6-6E98-4C0D-BE33-2BBDC9499D0D

28 U.S.C. § 1746 DECLARATION OF MAGGIE BERG IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 8/25/2012 to 12/1/17. Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a Integrated Claims Examiner, Integrated Claims Examiner II, AMS Claims Examiner, and Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I did not hold any insurance licenses or other licenses relevant to my position. Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having a college degree or any specialized licensure.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of

Exhibit A-K

DocuSign Envelope ID: BAFD91B6-6E98-4C0D-BE33-2BBDC9499D0D

action for nearly every contingency I encountered during my employment—to perform my work in a highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: BAFD91B6-6E98-4C0D-BE33-2BBDC9499D0D

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 50 Claims Examination Employees in Oregon and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers, including Dev Devrat, Kelly Curren, and Jasko Kokovich, would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/12/2020

Executed on _______________________

_______________________ MAGGIE BERG

Exhibit A-K

DocuSign Envelope ID: D88E0E38-D09C-453A-9F30-6427DA3C71B5

28 U.S.C. § 1746 DECLARATION OF MARY FLOYD IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 11/1/2017 to 7/26/18. Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a Claims Examiner, Claims Examiner I, Claims Examiner II, and Senior Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I did not hold any insurance licenses or other licenses relevant to my position. Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having a college degree or any specialized licensure.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of action for nearly every contingency I encountered during my employment—to perform my work in a

Exhibit A-K

DocuSign Envelope ID: D88E0E38-D09C-453A-9F30-6427DA3C71B5

highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee on a remote basis from home.

Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: D88E0E38-D09C-453A-9F30-6427DA3C71B5

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed several hundred Claims Examination Employees across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; and (3) training seminars I attended with other Claims Examination Employees.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers, including Jennifer Hassell, would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/13/2020

Executed on _______________________

_______________________ MARY FLOYD

Exhibit A-K

DocuSign Envelope ID: 11BB28EB-A536-493D-A352-B5393609B330

28 U.S.C. § 1746 DECLARATION OF MICHAEL MCDONALD IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 11/14/2016 to 9/10/19.

Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a Absence Management Specialist, Absence Management Specialist 2, and AMS Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I was not a college graduate and did not possess any type of specialized license relevant to my position.

Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having a college degree or any specialized licensure.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of

Exhibit A-K

DocuSign Envelope ID: 11BB28EB-A536-493D-A352-B5393609B330

action for nearly every contingency I encountered during my employment—to perform my work in a highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: 11BB28EB-A536-493D-A352-B5393609B330

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 150 Claims Examination Employees in Arizona and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers, includingPaul Tuck, Mike Tuck, and Jaz Taihreen, would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/14/2020 Executed on _______________________

_______________________ MICHAEL MCDONALD

Exhibit A-K

DocuSign Envelope ID: 86B030AF-1840-4456-82DA-41B292E22623

28 U.S.C. § 1746 DECLARATION OF TINA WEEKS IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 6/9/2014 to 12/28/18. Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a LTD Claims Examiner, Integrated LTD Claims Examiner, Integrated Claims Examiner, and Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I was not a college graduate and did not possess any type of specialized license relevant to my position.

Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having a college degree or any specialized licensure.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of

Exhibit A-K

DocuSign Envelope ID: 86B030AF-1840-4456-82DA-41B292E22623

action for nearly every contingency I encountered during my employment—to perform my work in a highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: 86B030AF-1840-4456-82DA-41B292E22623

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 200 Claims Examination Employees in Arizona and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers, including Ronda Hacket, Vali Soto, and David Cruz, would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

7/15/2020

Executed on _______________________

_______________________ TINA WEEKS

Exhibit A-K

DocuSign Envelope ID: 0432CA78-C102-4505-BB5F-4C70DF2BAAE2

28 U.S.C. § 1746 DECLARATION OF SANDRA MATOS IN SUPPORT OF PROCEEDING AS A COLLECTIVE ACTION 1.

Matrix Absence Management, Inc.’s (“Matrix” or “Defendant”) is a third-party administrator that processes leave of absence and disability claims for employers. Matrix employed me and other non-management workers (“Claims Examination Employees”) to produce the ongoing, day-to-day insurance claims processing services that Matrix provides to its customers.

2.

As a Claims Examination Employee, my primary job duty consisted of processing insurance claims in accordance with predetermined guidelines within specified time frames. My daily job duties included (1) requesting and gathering medical and employment information from claimants, employers, and medical offices, (2) sharing information and documents with supervisors/managers and other specialized staff, such as nurses and vocational experts, to receive guidance on how to process claims; (3) inputting information into Defendant’s computer system and into template approval/denial letters to claimants; (4) review claims against approval criteria and policy conditions; (5) populating template approval/denial letters and sending to my supervisor for review and approval and revising letters as directed; (6) mailing template denial/approval letters to claimants; (7) calling claimants to inform them of decisions to deny or approve claim; and (8) meeting all company-imposed deadlines (collectively, “Claims Examination Work”).

3.

As a Claims Examination Employee, the only time I was allowed to deny a claim without approval from a supervisor was if a claimant failed to provide necessary documentation by Matriximposed deadlines. In such cases, I would mail the claimant a form denial letter.

4.

At Matrix, claims were approved or denied based on whether they met specific, predetermined criteria. If the criteria were met, I would send a template approval letter. In such cases, I would use the formula set forth in the policy, typically 60% of the employee’s weekly earnings, to calculate the amount due on the claim. If the claim did not meet Matrix’s criteria, Matrix company policy required me to send the claim and a proposed denial letter to my supervisor to determine whether Matrix would approve or deny a claim for not meeting the requisite criteria.

5.

Matrix employed me as a Claims Examination Employee from 5/22/2008 to 5/14/18. Matrix referred to my “technical” job title in multiple ways during my employment, including referring to me as a Integrated Claims Examiner, Absence Management Specialist, and AMS Claims Examiner. In fact, Matrix collectively referred to other Claims Examination Employees and I as “Claims Examiners” during my employment. Regardless of the way Defendant referred to my position during my employment, my job duties remained the same and primarily consisted of Claims Examination Work.

6.

Matrix did not require a college degree or any type of license, including either a clinical license or insurance license, to perform the Claims Examination Work performed by me and other Claims Examination Employees. For example, during my employment as a Claims Examination Employee, I was not a college graduate and did not possess any type of specialized license relevant to my position.

Moreover, I also worked with other Claims Examination Employees who qualified for their positions despite not having a college degree or any specialized licensure.

7.

I performed my work as a Claims Examination Employee in accordance with Matrix’s policies, procedures, guidelines, and criteria and guidelines/criteria embedded in Matrix’s computer software.

Matrix provided me with training on how to use these decision-making tools—detailing a course of action for nearly every contingency I encountered during my employment—to perform my work in a

Exhibit A-K

DocuSign Envelope ID: 0432CA78-C102-4505-BB5F-4C70DF2BAAE2

highly consistent and accurate manner. I could not significantly deviate from Matrix’s guidelines or criteria to perform my Claims Examination Work.

8.

Other Claims Examination Employees and I had little authority to make many claims decisions on our own. Rather, our supervisors were regularly responsible for deciding whether to take certain actions on a claim (such as rejecting or terminating the claim), and nursing/vocational staff rendered opinions that were necessary for claim decisions. While I had the authority to deny a claim based on a claimant’s failure to meet deadlines to provide necessary documentation, I had no authority to deny claims for failure to meet coverage criteria or for any other substantive reason. This is because Matrix had a strict policy that required my supervisor—at all times—to retain ultimate authority over whether Defendant would deny a claim for failure to meet coverage criteria.

9.

I performed my work as a Claims Examination Employee in an office environment. Defendant provided me with the necessary computer equipment and electronic access to perform my work this way. Regardless of where I performed my Claims Examination Work, my job duties remained the same and primarily consisted of Claims Examination Work.

10.

Other Claims Examination Employees and I had no direct reports and no authority to delegate work, hire, fire, or discipline other employees. Moreover, as a Claims Examination Employee, I was a rule follower, not a rule maker. I had no role or involvement in creating or changing the policies, procedures, guidelines or criteria that Defendant required me to adhere to in performing my Claims Examination Work. Rather, I processed claims assigned to me in accordance with the procedures and guidelines dictated by Matrix through initial and ongoing training, claims manuals, directives from supervisors and managers, and other claims-handling instructional information. My supervisor regularly reviewed my claim files to determine whether I had complied with various company procedures and guidelines. Failure to meet Matrix’s production or accuracy requirements in applying its policies, procedures and guidelines would have resulted in poor performance reviews, corrective action, and potential termination. Additionally, failure to meet “Matrix Best Practices”—mandatory deadlines Matrix required us to meet in the claims process—would have resulted in poor performance reviews, corrective action and potential termination.

11.

The work I performed as a Claims Examination Employee was not directly related to the management or business operations of Defendant’s customers. This is due, in part, to the fact that as a Claims Examination Employee, I dealt principally with insurance benefit claimants—not with Defendant’s customers. Moreover, my role as a Claims Examination Employee did not involve (1) providing consultation or expert advice to management; or (2) setting short- or long-term business goals with respect to either Defendant or its customers. Instead, as a Claims Examination Employee, I was a production worker that performs the claims-processing services that Defendant is in business to sell to its customers.

12.

As a Claims Examination Employee, I had no involvement with litigation or authority to retain outside experts to evaluate a claim. Nor did my job duties include inspecting property damage, using discretion to determine claim coverage, assigning percentage of fault to parties, setting or adjusting reserves, using discretion to determine claim coverage, negotiating or settling claims, or using discretion to determine the amount Matrix paid on claims. Instead, the amounts paid on approved claims were calculated pursuant to formulas provided by Matrix and failure to accurately calculate claim amounts pursuant to these formulas would have subjected me to poor performance reviews, corrective action, and potential termination.

Exhibit A-K

DocuSign Envelope ID: 0432CA78-C102-4505-BB5F-4C70DF2BAAE2

13.

As a Claims Examination Employee, I routinely worked over 8 hours per workday and over 40 hours per workweek. Despite regularly working over 40 hours per week, Matrix denied me overtime pay for all overtime hours worked. Instead of paying me overtime Matrix subjected me and other Claims Examination Employees to its companywide policy that classified us all as exempt, paid us a salary, and denied us overtime pay for all the overtime hours we worked.

14.

Based on my experience working for Matrix, I understand that Matrix employed at least 100 Claims Examination Employees in California and several hundred more across the country who worked under the same conditions as I did during my employment. Like me, these Claims Examination Employees primarily performed Claims Examination Work, regularly worked overtime, and were subjected to Matrix’s policy that that denied Claims Examination Employees overtime pay for all overtime hours we worked. The duties, hours and pay policies did not depend on where we performed our work.

15.

I base my belief and knowledge of Matrix’s policies and pay practices on (1) conversations I had during my employment with other Claims Examination Employees who talked to me about their job duties, hours of work, and how Matrix paid them; (2) training calls/webinars that I attended with Claims Examination Employees; (3) training seminars I attended with other Claims Examination Employees; and (4) observations of other Claims Examination Employees performing Claims Examination Work while working hours similar to those I worked while working for Matrix in an office environment.

16.

I am informed and believe that other current and former Claims Examination Employees subjected to Matrix’s misclassification scheme would join this case if they were aware of its existence.

I do not presently recall the names, telephone numbers, and addresses of all of the individuals with whom I worked while at Matrix; however, I believe multiple of my Claims Examination Employee coworkers would join this case (or may have already done so) or would be eligible to do so if they knew of its existence and were not afraid of retaliation.

17.

I know that other Claims Examination Employees and I rely/relied heavily on our cell phones and computers for both personal and professional communications based on my conversations with coworkers. I personally use/used my cell phone and computer to communicate with friends, family and attorneys through email, text message and phone calls. In fact, while working for Matrix, managers and other co-workers would often contact me by text or phone call—rather than by mail or email— about work. Although I receive mail, I also routinely receive a significant amount of junk mail. If I did not know anything about this case, I would be far more likely to receive and read a notice that was emailed and/or texted to me.

I declare under penalty of perjury that the foregoing is true and correct.

8/6/2020 Executed on _______________________

_______________________ SANDRA MATOS

Exhibit A-K