In their petition, the workers said $9,602.50 is a reasonable award for their efforts to obtain and then compel discovery from Gold Mantis.

“Plaintiffs request that Gold Mantis be ordered to pay this amount within 14 days, rather than the usual 30 days, due to its record of disobeying court orders,” the workers stated in the petition.

Represented by attorneys Aaron Halegua and Bruce Berline, the plaintiffs are Tianming Wang, Dong Han, Yongjun Meng, Liangcai Sun, Youli Wang, Qingchun Xu and Duxin Yan.

The plaintiffs previously worked for MCC International and Gold Mantis, the former contractor and subcontractor of Imperial Pacific International.

They initially sued MCC International and Gold Mantis only, but included IPI in their amended complaint.

They have accused the defendants of committing labor violations and human trafficking.

At the Nov. 25, 2020 hearing, the court ruled that the  plaintiffs are entitled to attorney’s fees.

The plaintiffs said their efforts to “compel Gold Mantis to comply with the discovery order required a significant amount of work by numerous attorneys and others.”

When Gold Mantis  ignored the court’s discovery order, the plaintiffs added, they “prepared a status report alerting the court to this fact as well as requested specific sanctions be imposed on Gold Mantis….”

In addition, the plaintiffs said they drafted a proposed order to show cause and submitted it to the court.

Once the court issued the order to show cause, Gold Mantis filed an “answer,” including a legal brief and two affidavits.

The plaintiffs then filed their own response. “This required plaintiffs to review the brief and affidavits submitted by Gold Mantis; review the production of financial and bank records by Gold Mantis; and research cases to support appropriate sanctions against Gold Mantis for its noncompliance.”

The plaintiffs said that on the day of the hearing on the order to show cause, Gold Mantis submitted two more affidavits. “Plaintiffs were required to review these affidavits, compare them to prior affidavits that had been submitted, and compare them against the requirements of the discovery order. In addition, Plaintiffs needed to prepare for and participate in the [order to show cause] hearing on Nov. 25.”

Finally, “plaintiffs spent additional hours preparing this fee petition.”

For all of these tasks, the plaintiffs are requesting an award based on the work performed by Halegua and Berline who were assisted by attorney Times Wang.

“The requested hours are supported by the contemporaneous time records maintained by each of the aforementioned individuals,” the plaintiffs stated.

Specifically, they are requesting 19.35 hours for Halegua; 5.10 hours for Berline and 0.95 hour for Wang.

Halegua’s hourly rate is $400; Berline’s, $300; and Wang’s, $350. 

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