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RETAINER AGREEMENT

I, _______________________________, hereby retain Erin Brokovich, Esq. and Law Group, P.C. (Law Group) to represent me in connection with a potential legal action against _________________________________ for violations of the Fair Debt Collection Practices Act (15 U.S.C. 1692, et seq.) and other federal and state laws. LEGAL SERVICES Unless this agreement is changed or canceled in writing by Law Group or myself as set forth below, Law Group agrees to bring claims I may have against the above mentioned defendant(s) in an appropriate court, and to pursue those claims on my behalf competently and diligently. Law Group will serve as the lead counsel in the litigation and will be responsible for all communications with me, including, but not limited to, keeping me advised as to the progress of the case. In the event that I receive a negative decision on my claim, Law Group will review again the legal claim to determine whether it will provide me with legal representation in an appeal of the decision. Similarly, if a separate legal action or the defense of a counterclaim becomes necessary as part of the litigation of my claim, Law Group will have the right to determine whether to provide me with the legal representation in any such separate case or defense of a counterclaim pursuant to a separate written agreement at a fee to be agreed upon at that time. ATTORNEYS FEES/COSTS I understand that I will not be required to pay any attorneys fees to Law Group other than through a deduction for the payment of reasonable fees from a common fund created as part of the settlement of the class claims filed, or judgment entered, in the action as set forth below. I further understand that my case is one in which defendant(s) may be required to pay reasonable attorneys fees to Law Group and. I authorize Law Group to seek and collect reasonable attorneys fess in addition to any relief they are seeking for me. I agree that Law Group may keep any attorneys fees that are obtained through court or agency order or settlement of the case pursuant to the provisions of the Co-Counseling Agreement, if such an agreement exists. I understand that Law Group may have to pay certain costs in order to properly represent me in this case. These costs may include filling fees, fees for service of process and subpoenas, expert witness fees, stenographers fees and other expenses related to litigation. Whenever possible, Law Group will try to have defendant(s) pay for the costs. If Law Group cannot obtain payment of costs from defendant(s) and I receive an award of money in this case, I agree to repay Law Group for all costs for my case from the money I receive. I further understand that I may not impose a requirement to incur costs that the attorneys feel are not reasonable unless I am willing to advance and pay those costs myself.

I understand that, if my case is not successful and the court rules that the case is frivolous, unreasonable, or groundless, the court may order me to pay defendants litigation costs and/or attorneys fees. In the event of such a court order, Law Group agrees to pay the entire amount of defendant(s) fees and litigation costs awarded, except that: I agree that, I alone, will be responsible for the payment of such an award if (1) I misstate the facts to Law Group and the court award is based upon facts found to be substantially and materially different than I have stated them; or (2) I refuse a settlement offer which Law Group considers reasonable under the circumstances and/or given the objectives of the litigation. I also understand that, other than litigation costs, I alone am responsible for paying any fines, penalties, or damages assessed against me personally. SETTLEMENT I understand that it may be possible to settle my case Law Group will keep me informed of any settlement offers and consult with me about how to respond to any offers. No settlement will be made without my approval. Law Group and I will make the best efforts to obtain a settlement that will adequately meet each of the following goals, with no single goal taking precedence over any other goal: (a) produce systemic reform of defendant(s) policies or practices so other consumers will benefit from this litigation; (b) satisfy my individual goals; and (c) compensate Law Group fairly for their reasonable attorneys fees and litigation costs. I understand that as a public interest counsel, Law Group face competing goals in seeking to maximize my personal recovery and in seeking reasonable attorneys fees and costs. In order to satisfy both interests, I authorize Law Group to negotiate a resolution of the class claims and my individual claims separate from any negotiation of attorneys fees and litigation costs. In the event that Law Group is unable to reach a settlement on the issues of attorneys fees and costs, I understand that Law Group may make an application to the Court for an award of attorneys fees and costs as a prevailing party. I further understand that in making such application, Law Group will calculate their fees using the loadstar method that reflects the number of hours worked multiplied by a reasonable hourly rate. I agree that Law Group may be entitled to a multiplier, or enhancement, of the loadstar amount due to the novelty, complexity and speculative nature of the claims brought in this matter. I understand that defendant(s) may make a settlement offer that does not include a breakdown between my damages and attorneys fees or litigation costs or otherwise requires me, as a condition of settlement, that I waive any claim for attorneys fess or litigation costs. Regardless, Law Group will convey to me any settlement offer made by defendant(s), even if it is conditioned on my waiving these fees and costs. I understand that Law Groups recommendations concerning the advisability of accepting or rejecting such a settlement proposal may reflect the fact that it is conditioned on my waiving attorneys fees or litigation costs. I understand that, if I agree to a lump sum monetary settlement of all my claims against defendant(s), including attorneys fees, then the attorneys fees to be paid to Law Group will be thirty three percent (33%) of the settlement, excluding expenses and costs, or attorneys fees calculated pursuant to the loadstar method, whichever is greater. Costs

and expenses incurred by Law Group will be taken off the top before computing this amount. In the event that I agree to a monetary settlement which delineates the amount to be paid for my claims against defendant(s) and the amount to be paid for attorneys fees, expenses and costs, then I agree that Law Group will be paid their legal fees, expenses and costs in accordance with the terms of the settlement agreement. CLIENT RESPONSIBILITIES I agree to make a full and honest disclosure to Law Group of all facts relevant to my case, including new facts that may arise during the course of my case. I will keep Law Group informed of my current address and telephone number. As a client of Law Group, I understand that I have the responsibility to keep them informed of any significant changes in my circumstances, including any changes in my financial condition. I will promptly inform Law Group, if I should receive any settlement offers, documents or other communications directly from defendant(s) or any third parties in regards to this matter. I understand that, as my counsel, Law Group is to conduct all communication on my behalf with regard to this matter. I agree that I will not initiate any communication I might receive from defendant(s) or third parties in regards to this matter. I understand that I may have to appear in court or attend a deposition and will assist, and cooperate with Law Group, to the fullest extent possible in its representation of my interests in this matter. I also understand that this case may be certified as a class action lawsuit and that in making any decisions concerning this case, my attorneys and I must consider, in addition to my own interests, the interests of the class of people for whom I am representative. In the event that I enter into a settlement of the class action with defendant(s) that is not recommended by my counsel, I recognize that Law Group reserves the right to seek approval from the Court to withdraw as counsel if they believe that the terms of the proposed settlement do not adequately address the interests and claims of the putative or certified class. If at some time in the future my income or assets exceed Law Groups eligibility guidelines, I understand that Law Group may no longer be able to represent me and I may have to obtain other counsel. Law Group will assist me in obtaining other counsel and will continue to represent me until appropriate arrangements are made. COUNSEL RESPONSIBILITIES Law Group agrees to handle my case competently and diligently, to exercise professional judgment free from any conflict of interest, to alert me of important developments in my case, and to respond promptly to my reasonable requests for information about my case. TERMINATION I understand that I am free at any time to discharge Law Group from representing me by written letter. However, if I choose to discharge Law Group, the remaining counsel (if any) is under no obligation to find a replacement or to continue representation of me. In

addition, if after discharging Law Group I thereafter recover monetary relief through settlement or trial, I agree to pay Law Group their normal hourly rates, up to the amount of recovery, for the services actually provided to me in the case prior to the time of discharge and for all litigation costs and expenses expended by Law Group on my behalf. I agree that Law Group may, upon giving reasonable written notice, seek to terminate their involvement in my case if (a) the case becomes frivolous, unreasonable, or groundless in their view, or (b) the facts of my case are found to be materially and significantly different than I have stated them, or (c) the representation of me requires taking a position contrary to the public interest as determined by Law Group, or (d) I refuse a settlement offer which Law Group considers reasonable under the circumstances and/or given the objectives of the litigation, or otherwise fail to cooperate. If Law Group terminates their involvement in my case under any of these circumstances, I agree that they will retain their right to recover their costs and the market value of their legal services from me. PUBLICITY Law Groups cases are of public interest, and Law Group often seeks to further the rights of other by publicizing the cases it supports and the outcome of those cases. I understand that Law Group may make recommendations to me concerning such publicity. Based on the public need to know the law and the facts of my case, I agree to reasonably cooperate with such efforts. Ultimately, however, I retain the right to decide whether Law Group may publicize aspects of my case that are not already part of the public record. MISCELLANEOUS I recognize that no results have been guaranteed by Law Group to me and that this Retainer Agreement is not based upon any such promises or anticipated results. I further acknowledge that I am exclusively responsible for any personal liability, or potential liability, awarded against me by the court for any claim or counterclaim and that, by undertaking to represent me pursuant to this Retainer Agreement, Law Group assume none of my personal liability.

_____________________ Plaintiff Representative

_________________ Date

_____________________ Erin Brokovich, Esq., on behalf of Law Group

_________________ Date

_____________________ on behalf of Co-Counsel (if any)

__________________ Date

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