Seven individuals filed a collective action lawsuit against Bassam Odeh, Inc. and Bassam Mohammed Odeh on behalf of themselves and other similarly situated employees. In support of their motion to conditionally certify the collective action and issue notice, the plaintiffs submitted declarations from five of the named plaintiffs describing their employment experiences. The plaintiffs also submitted a New York Times article, a proposed notice to putative class members, and a proposed consent to join form.

1. IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
BRENDA AGUAYO, MARIA
MALDONADO, MARIA CLIMACO, OLIVIA
ORTIZ, ANA PALOMARES, SUSANA
MARTINEZ AND NICANOR QUIROZ, on
behalf of themselves and all others similarly
situated,
Plaintiffs,
V.
BASSAM ODEH, INC. AND BASSAM
MOHAMMED ODEH
Defendants.
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
CIVIL ACTION NO. 3:13-CV-02951-B
PLAINTIFFS’ APPENDIX IN SUPPORT OF THEIR
MOTION TO CONDITIONALLY CERTIFY A COLLECTIVE ACTION
AND TO ISSUE NOTICE
Pursuant to Local Rules 7.1(i) and 7.2(e), Plaintiffs file this Appendix in Support of their
Motion to Conditionally Certify a Collective Action and to Issue Notice. Each page of this
Appendix is numbered sequentially in the lower, right-hand corner.
Plaintiffs rely on the following in support of their Motion in addition to the filings and
pleadings in this case.
Exhibit Document Pages
A Declaration of Brenda Aguayo 1 - 4
B Declaration of Maria Maldonado 5 - 8
C Declaration of Olivia Ortiz 9 - 12
D Declaration of Maria Climaco 13-16
E Declaration of Nicanor Quiroz 17-20
Case 3:13-cv-02951-B Document 6 Filed 07/31/13 Page 1 of 3 PageID 57

2. -2-
F Article from the New York Times, “Energy Efficiency
Comes to Fast Food,” dated August 25, 2009
21-22
G Proposed Notice to the putative class members 23-25
H Proposed Consent to Join form 26-27
By: /s/Allen R. Vaught
Allen R. Vaught
Baron & Budd, P.C.
State Bar No. 24004966
3102 Oak Lawn Avenue, Suite 1100
Dallas, Texas 75219
(214) 521-3605 – Telephone
(214) 520-1181 – Facsimile
avaught@baronbudd.com
Paula Wyatt
TX Bar No. 10541400
The Wyatt Law Firm
70 NE Loop 410, Suite 725
San Antonio, Texas 78216
(210) 340-5550 – Telephone
(210) 340-5581 – Facsimile
pwyatt@wyattlawfirm.com
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document will be served
with the Original Complaint and Summons in this case by private process server. The date of
service will be confirmed by the proof of service as completed by the process server.
Additionally, I hereby certify that a true and correct copy of this document was served on
Defendants, as listed below, along with a copy of the Complaint and Summons via certified mail,
return receipt requested, and placed into an official depository of the United States Postal
Service, on this the 1st
day of August 2013:
Defendant Bassam Odeh, Inc.,
c/o registered agent, Mr. Bassam M. Odeh
502 North O’Connor Road
Irving, Texas 75061-7528
CMRRR 7160 3901 9848 4711 1666
Case 3:13-cv-02951-B Document 6 Filed 07/31/13 Page 2 of 3 PageID 58

3. -3-
Defendant Bassam M. Odeh
6542 Potomac Parkway
Arlington, Texas 76017-4934
CMRRR 7160 3901 9848 4711 1673
/s/Allen R. Vaught
Allen R. Vaught
Case 3:13-cv-02951-B Document 6 Filed 07/31/13 Page 3 of 3 PageID 59