1 HUNTER PYLE, SBN 191125 KATHERINE FIESTER, SBN 301316 2 HUNTER PYLE LAW 3 428 Thirteenth Street, 11th Floor Oakland, California 94612 4 Telephone: (510) 444-4400 Facsimile: (510) 444-4410 5 [email protected] [email protected] 6

7 MONIQUE OLIVIER, SBN 190385 KATHARINE CHAO, SBN 247571 8 OLIVIER SCHREIBER & CHAO LLP 201 Filbert Street, Suite 201 9 San Francisco, California 94133 Telephone: (415) 484-0980 10 Facsimile: (415) 658-7758 11 [email protected] [email protected] 12 Attorneys for Plaintiff EVAN TOOLAJIAN and the Proposed Class 13

14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 SAN FRANCISCO DIVISION 17

18 EVAN TOOLAJIAN on behalf of himself and Case No. 3:18-cv-06722-AGT all others similarly situated; [PROPOSED] ORDER GRANTING 19 PLAINTIFF’S MOTIONS FOR (1) FINAL Plaintiff, APPROVAL OF CLASS ACTION 20 SETTLEMENT, AND (2) ATTORNEYS’ v. FEES, COSTS, AND CLASS 21 REPRESENTATIVE SERVICE AWARD

[AS MODIFIED] 22 AIR METHODS CORPORATION, a Delaware corporation, and DOES 1 through 10, inclusive, Date: July 31, 2020 23 Time: 10:00 a.m. Defendants. Ctrm.: A, 15th Floor 24 Judge: Hon. Alex G. Tse

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27 1 These matters came on for hearing via Zoom video conference on July 31, 2020, at 10:00 2 a.m., before the Honorable Alex G. Tse of the United States District Court for the Northern 3 District of California. Due and adequate notice having been given to the Settlement Class (as 4 defined below), and the Court having considered all papers filed and proceedings held herein, all 5 oral and written comments and any objections received regarding the proposed settlement, having 6 reviewed the record in the above captioned matter, and good cause appearing therefor, 7 IT IS HEREBY ORDERED, ADJUDGED AND DECREED AS FOLLOWS: 8 1. The Court has jurisdiction over the subject matter of the above-captioned action 9 (the “Action”), Evan Toolajian (“Class Representative”), Defendant Air Methods Corporation 10 (“AMC” or “Defendant”), and all members of the Class, which is defined as follows: 11 All current and former Pilots employed by Air Methods Corporation in California at any 12 time during September 20, 2014 to April 24, 2020. 13 2. The terms “Settlement” or “Settlement Agreement” shall refer to the Amended 14 Joint Stipulation of Class Action Settlement and Release filed by the Class Representative on 15 April 3, 2020 (Dkt. No. 53), and all terms herein shall have the same meaning as the terms defined 16 in the Settlement Agreement, unless specifically provided herein. 17 3. The Court grants final approval of the Settlement Agreement because it meets the 18 criteria for final settlement approval. The Settlement falls within the range of possible approval as 19 fair, adequate and reasonable, appears to be the product of arm’s-length and informed 20 negotiations, and treats all members of the Class fairly. 21 4. The Court finds that the distribution by U.S. first-class mail of the Class Notice 22 constituted the best notice practicable under the circumstances to all persons within the definition 23 of the Class, and fully met the requirements of due process under the United States Constitution 24 and applicable state law. Based on evidence and other material submitted in conjunction with the 25 Final Approval Hearing, the Notice to the Class was adequate. The Notice informed members of 26 the Class of the terms of the Settlement, their right to object to the Settlement or Plaintiff’s Motion 27 for Attorneys’ Fees and Costs and the Class Representative’s Service Award, their right to appear 1 in person or by counsel at the Final Approval Hearing, and their right to exclude themselves from 2 the Settlement and pursue their own remedies. Adequate periods of time were provided by each 3 of these procedures. 4 5. The Court finds, for purposes of settlement only, that the Class satisfies the 5 applicable standards for certification under Federal Rules 23(a) and 23(b)(3). Accordingly, solely 6 for purposes of effectuating this Settlement, this Court has certified the Class, as defined above. 7 Because the Class is being certified here for settlement purposes only, the Court need not (and 8 does not) address the manageability requirement of Rule 23(b)(3). See Amchem Products, Inc. v. 9 Windsor,

(1997). 10 6. The Court approves the Settlement and the Released Claims and other terms set 11 forth in the Settlement Agreement as fair, reasonable and adequate. The Parties and the 12 Settlement Administrator are directed to perform in accordance with the terms set forth in the 13 Settlement Agreement. 14 7. Except as to any individual member of the Class who has validly and timely opted 15 out of the Settlement, all of the claims asserted in the Action are dismissed with prejudice. The 16 Parties are to bear their own attorneys’ fees and costs, except as otherwise provided in the 17 Settlement Agreement and this Order. 18 8. By this Judgment, the Class Representative and each member of the Class who has 19 not validly and timely requested exclusion from the Settlement by opting out, hereby release AMC 20 and the Released Parties (as defined in the Settlement Agreement) from the Released Claims (as 21 those terms are defined in the Settlement Agreement). 22 9. The Action is dismissed on the merits and with prejudice, permanently barring the 23 Participating Class Members from prosecuting any of the Released Claims. The Court reserves 24 and retains exclusive and continuing jurisdiction over the Action, the Class Representative, the 25 Class, and AMC for the purposes of supervising the implementation, effectuation, enforcement, 26 construction, administration and interpretation of the Settlement Agreement and this Judgment. 27 1 10. The Court finds that the plan of allocation for the shares of the Gross Settlement 2 Amount as set forth in the Settlement Agreement is fair and reasonable, and that distribution of the 3 Net Settlement Amount shall be done in accordance with the terms outlined in the Notice and 4 Settlement Agreement. 5 11. The Court hereby orders the appointment of Plaintiff Evan Toolajian as Class 6 Representative for the Class for purposes of settlement. 7 12. The Court hereby orders the appointment of Hunter Pyle of Hunter Pyle Law and 8 Monique Olivier and Katharine Chao of Olivier Schreiber & Chao LLP as Class Counsel for 9 purposes of settlement. 10 13. The Settlement Administrator shall pay from the Gross Settlement Amount: (i) the 11 Settlement Administrator for its reasonable fees for its services; and (ii) the Service Award to the 12 Class Representative to reimburse him for his valuable services to the Settlement Class. The 13 Court hereby approves the payment of settlement administration costs in the amount of $7,000 to 14 Simpluris, Inc., the Settlement Administrator, for services rendered in this matter. The Court also 15 approves the Service Award to the Class Representative in the amount of $10,000 for his valuable 16 services in initiating and maintaining this litigation, the risks he undertook in bringing this Action, 17 and the benefits conferred onto the Settlement Class. The Court finds that these payments are fair 18 and reasonable. The Settlement Administrator is directed to make the foregoing payments in 19 accordance with the terms of the Settlement Agreement. 20 14. The Court hereby awards to Class Counsel the amount of $490,000 for attorneys’ 21 fees, and the amount of $12,406.54 for costs. Based on Plaintiff’s Motion for Attorneys’ Fees, 22 Costs, and Class Representative Service Award (Dkt. No. 55), the Court finds that Class Counsel 23 advanced legal theories on a contingent-fee basis, that their efforts resulted in a substantial 24 monetary recovery for the Class, and that the requested attorneys’ fees awarded are reasonable. 25 The Court finds this payment to be fair and reasonable. The Settlement Administrator is ordered 26 to wire these funds to Class Counsel in accordance with the terms of the Settlement Agreement. 27 1 15. This document shall constitute a judgment for purposes of Rule 58 of the Federal 2 Rules of Civil Procedure. 3 IT ISSO ORDERED. 4 Dated: July 31, 2020 5 AL TSE 6 United States Magistrate Judge 7 8 9 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4- Case No.: 3:18-cv-06722-AGT