Re: [CLIENT NAME] v. Lyft, Inc.
We look forward to working with you to pursue your claims
against Lyft, Inc. (“Lyft”) related your employment with Lyft. This is an agreement
(the “Agreement”) between you and Milberg Coleman Bryson Phillips Grossman PLLC
(“MCBPG”). I, along with MCBPG attorneys and/or its co-counsel who are licensed
to practice law in, among other States, Washington, Oregon, and/or
Massachusetts, will be primarily responsible for your case. Although I am only
licensed to practice law in Illinois, our team at MCBPG includes attorneys
licensed across the country who will be working with me and others on your
understand and authorize MCBPG to proceed with filing your claims as an
individual arbitration, rather than in a court. Arbitration is a simplified
means of pursuing legal claims, where the claim is decided by an arbitrator
rather than a judge or jury and is overseen by an arbitral organization such as
the American Arbitration Association. Arbitration can be very different from a
court case. Unlike a court case, there is no jury in arbitration, and there is
limited discovery. Although we anticipate an arbitration, this agreement shall
apply regardless of whether the claims are filed in arbitration, in court, or
resolved by settlement prior to a filing in any forum. While it is MCBPG’s goal
to secure the maximum recovery possible for you in connection with your claims,
you authorize MCBPG to resolve and settle your claims with Lyft, at a minimum, in
the amount of $1,500.00.
firm will handle the above-referenced matter based upon a contingent fee
arrangement wherein our collective fee will be Forty Percent (40%) of any
recovery obtained in this matter, whether it be through settlement or judgment.
We reserve the right to associate any co-counsel that we deem advisable or
necessary for the proper handling of your claim. Our fee will be split among
our firm and any firm(s) we associate. This arrangement would not include any
appeal that may be subsequently taken by any party.
this litigation, we will incur expenses for copies, long distance telephone
calls, legal research, travel, etc. Typically, these costs are paid by the
client. However, we will advance all costs incurred by our firms, such as
copies, postage, express delivery charges, legal research (e.g., Westlaw,
LexisNexis, PACER), travel expenses, etc. We will also incur costs that are not
generated by our firm, such as the filing fees with the arbitral organization
or court, costs of the experts, legal process outsourcing companies (i.e.,
service of process, document production, trial exhibits), and deposition costs
(including transcripts). We will be reimbursed for these costs if, and only if,
we ultimately obtain a recovery. Advanced costs are deducted from the recovery
after the calculation of the contingent fee.
Please understand that MCBPG may at any time recommend
that the case not be continued for good and sufficient reasons including, but
not limited to, little or no likelihood for success on the claims’ merits, or
the lack of available sums, whether they be the assets of Lyft or applicable
insurance coverage. If we should make such a recommendation to discontinue, we
may withdraw our representation upon due notice.
understand that your file and any materials compiled by our firms during
representation will remain the property of our firms upon conclusion of the
representation. We will cooperate fully in furnishing a copy of relevant
materials from the file to any successor attorney who you may retain. Additionally,
we will maintain the file on this matter for at least six (6) years. Should you
wish to obtain any information or materials from the file, including personal
items furnished to us in the handling of your case (i.e., documents,
photographs), these will be returned to you by request if the request is made
within six (6) years after the conclusion of the representation.
we do not make any promises or guarantees regarding the outcome or conclusion
of your claims.
you have any questions about the foregoing, please advise. We would appreciate
your returning a signed copy of this engagement letter to us for our
We look forward to working with you on this matter.