.,
`
`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 1 of 25
`FILED BY Fr; D.C.
`
`VASSILIOS KUKORINIS V WALMART, INC.
`CASE 1: 19-cv-20592-JEM -MARTINEZ/OTAZO-
`
`SEP 2 5 2020
`ANGELA E. NOBLE
`CLERK U.S. DIST. CT.
`S. 0 . Of FLA.· MIAMI
`
`Page 1 of 13
`09/22/2020
`
`DECLARATION OF VASSILIOS KUKORINIS PLAINTIFF'S REPRESENTATIVE IN
`SUPPORT OF PLAINTIFF'S OBJECTION OF THE SETTLEMENT, and reasons for
`denning the service award "price".
`
`Your Honors
`
`Up to this moment I have no personal knowledge of the matters stated in the motion for
`preliminary approval of the settlement, and the Plaintiffs' attorneys have not discussed,
`explained, or asked my opinion or approval.
`
`According to RETAINER AGREEMENT when I employed the law firm of Morgan &
`Morgan, my Duties as Client and a Class Representative, among others, were to be generally
`knowledgeable with respect to the subject matter and progress of the lawsuit, and represent the
`interests of all members of the class, as I would consider my own interests.
`
`Also # 8 Scope of Services Morgan & Morgan's Duties, were to Keep Client reasonably
`informed of the status of this matter.
`
`Unfortunately the Plaintiffs attorneys fail to keep this promise, and as a result I learned
`recently about
`the "successful" PRELIMINARY APPROVAL OF CLASS ACTION
`SETTLEMENT - and everything else happened that last 8 months in this case carrying my
`name - from online search, when I googled "Kukorinis V. Walmart".
`
`The last contact -by e-mail- I had with plaintiff's attorney Mr. John A. Yanchunis (Bar No.
`324681), was Jan 2P1 2020, complaining about Wahn.art's delay to provide the National
`sales data, as agreed at Nov 19th mediation meeting.
`
`Today-eight months later- after purchasing and downloading the PDFs of the Case No. 1: 19-
`CV-20592-MARTINEZ/OTAZO-REYES, surprisingly I discovered that all the developments
`took place after January 2020, happened without the Class Action Representative being
`informed, participated or updated, especially for the decision and the terms of the settlement.
`
`Therefor I thank the parties, but I am refusing to accept the agreed Service Award money,
`because I don't want to participate to this fiasco/cover up and betrayal to all class action
`members, orchestrated without my knowledge.
`
`This letter/declaration is not reviewed, polished or corrected by an attorney, and since English
`it's not my first language, please excuse the plethora of grammatical and syntax errors, while I
`am trying to explain and express my thoughts. I am furious and disappointed because this
`attempt to stop the lasting Defendant's deceptive and unfair acts or practices, not only failed,
`additionally the victims/class members feel that is an insult to our intelligence and common
`sense.
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 2 of 25
`
`Page 2 of 13
`
`When MORGAN & MORGAN drafted the initial complaint, I protested to the attorneys by e(cid:173)
`mail, pointing out that looks extremely "poor" and not mentioning -besides the low-fake
`price/unit scheme for the reduced products- the many other different ways WALMART
`misleading, deceiving and overcharging customers by manipulating prices, promote fake
`"specials", false advertised tags, and scanning gimmicks. I asked them to get advantage of the
`countless digital and printed material/evidences I provided. I requested an in-person meeting
`(and turned down) in order to explain to them, how all these deceptions work, without the fraud
`been suspected or noticed by the customers, or the city's, state's, and government watch dogs.
`
`Mr Yanchunis replied that "didn't want to risk for a judge to view it as sensationalism"
`(whatever that means), and "the complaint is not intended to capture all the evidences, that is
`the purpose of the trial". And that was the plan when he responds to defendant's Motion to
`Dismiss.
`
`"Plaintiff hereby demands trial by jury of all claims in this Class Action Complaint".
`
`But today I found out that Jury Trial, will never take place.
`
`I believe it's important to mention that 3 years ago, when I started this quest at West Palm
`Beach, I was referred to another big shot Class Action Attorney, who considered the Law suit,
`as a Monster case, and he was going to quit his Big Law firm in, order to exclusively work on
`Walmart's class action. After collecting from me for 8 months the evidences I gathered, and
`stalling to file the complaint, I (suspected he was sleeping with the enemy) have to let him go
`and move to West Coast in search for a better lawyer. That was the reason I postponed my
`retirement, and I moved to Tampa to keep an eye to the new Law Firm (I was referred) and the
`progress of the case. Unfortunately, no better luck, since I have been again ignored, misled and
`denied even
`to a "Client to La
`er
`live meetin " before Covid 19
`andemic .
`
`For first time I met the attorneys on November 18th• 2018 in California to be present to pt
`attempted mediation. I was impressed how all participants (with the exception of mediator)
`declared that were bad in mathematics, and I was wondering how they are going to interpret
`analyze the sales data prepared by an expert, develop damages models, and determine
`statistically the amount potentially at issue overcharged, in this Litigation. The mediator Mis
`Yoshida suggested, instead of limiting the scope of that information to Florida sales, Walmart
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 3 of 25
`
`Page 3 of 13
`
`could provide nationwide sales data for the class period, and we should try to settle the whole
`"package".
`
`While I was waiting for months for Wal.mart to responds with the numbers, suddenly, I am
`reading on Internet, that I "vigorously prosecuted this case for the benefit of all class
`Members by filing Litigation, reviewing, pleading, conferring with my Counsel , and
`providing input at mediation and crafting AND APPROVING the SETTLEMENT!!!
`
`For the record, I do understand one thing or two about math. I traveled around the world
`since 80s as Ocean Going Ships Marine Captain, and then (no GPS) we relied to advance
`mathematics to calculate the cargos and determine the ships position using astronomical
`navigation. I also served as reserved officer in the NA VY as commander. Later, back to old
`country, I worked as (top) TV investigating reporter, and guess what was one of the most
`successful stories I investigated and exposed.
`A French multinational supermarket company (like Wal.mart), "invaded" the country and very
`soon controlled 85 % of the retail industry, erasing all the antagonism. Their secret? Bribing
`officials, aggressive advertising, so the media never bother them, and massive price
`manipulations and customer deception. Rarely somebody suspected how magically the prices
`changes from the shelve to cash register, and always UP. That is the (only) way to become a
`leader (so fast) in a so competitive market.
`When you overcharge from 20 - 300%, on top of the Gross margin profit, you can afford to
`pay for aggressive marketing/advertising, bribing consumers watch dogs, and raise 4 times up
`the amount of annual salary to Wal.mart's store managers in order to make them accomplishes
`(since they get commission of the extra profits).
`With a little Google research, everybody will discover the hundreds of million "invested"
`from Walmart in bribes to officials in countries like Mexico, India etc. As for the practices of
`price manipulation schemes, and inferior product baptized "premium" in Costa Rica, England,
`even to China also are well publicized. The differences with the USA are, that at the above
`countries' authorities, "Caught them many times red handed".
`Except for N.Y and California, where the AG. Offices investigated, convicted and fined them
`with multimillion dollar slaps, the majority of the states prefer not to poke the bear, all thought
`sometimes, Weights and Measures inspect retail locations with automated point-of-sale
`systems to verify if prices charged to consumers are the same as those posted, advertised,
`or quoted price (as the Law require).
`For unknown reasons I don't believe that happening to Wal.mart's stores, at the State of Florida.
`How do I Know that (you may ask)?
`Due to personal serious brain injury 4 years ago, and until I recover (partially) I started
`keeping electronically notes, photos and video to all the places I visited for shopping. Surprise
`surprise, soon I discovered by comparing my notes that Walmart raped me financially every
`time. At the beginning I thought was just the specific store. So, I captured with the cellphone all
`the crazy/unbelievable rip offs, created a Blog and send it as a complain to Arkansas Home
`office Customer Service, and e-mailed a link to every executive board member, as a wake-up
`call. Classically they ignored me, so I decided to investigate how much the cancer have spread.
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 4 of 25
`
`4 of13
`Three years past, and I visited hundreds ofWalmart stores, multi times all over Florida. I
`never been in any store more than 10 minutes, without to register hundreds (to each store), well
`documented evidences of various schemes/practices, which targeted middle and low class
`customers wallet, that don't have the luxury of time in order to spend an extra hour,
`to protest at long Customer Service Desk lines, for been lied, insulted, and cheated by
`overpaying. The attorneys call it OVERCHARGING, but the Thesaurus has dozens of
`synonyms like extortion, defraud, stiff, soak, surcharge, Gaz ump, fleece, plume, pluck,
`rob, hook, gouge, rip off, etc.
`Verb= Make or seek to make an excessive or unfair profit, especially illegally.
`Profiteer, racketeer, abuse, exploit, scalp, and simply put it "make someone pay through
`the nose".
`Ok all that are theory, let's talk evidences.
`At the "Amended Class Action Complaint" one of the overcharges, described as follow.
`_ On April 19, 2018, Plaintiff purchased a spiral ham at a Walmart store in Delray Beach,
`Florida. The yellow sales label stated a ham weighed 11.61 pounds at a unit price o/$0.64 per
`pound, but the total price on the yellow label stated $16.45. As alleged, Walmart received an
`extra $9.02 -the difference between $16.45 and $7.43- on the sale because the unit price
`
`re ected that the ham should have on! cost $7.43 ----
`
`This is accurate description but it's not the whole story. When the cashier scanned the yellow -
`reduced-tag at the register, the monitor (and the "system ") charge me magically the initial
`/Full Price. More than $25. I pointed out the "phenomenon", and the cashier voided and re(cid:173)
`scanned it. This time the monitor shows $16.45 Of course, still is not adds up since,
`
`11 pounds X $ 0.64/LB should be about $7 not$ 16 (120% more). I requested to cancel it,
`and cashier called the manager. I explained the situation and he very rudely, respond "you are
`not going to get this ham for $7''. He used his phone calculator to persuade me that I was
`wrong, but the result proved him wrong. Finally, he admits that something is not adding up,
`and blame "The Computer (from Arkansas Home Office) does it, and the store just scan the
`product and print the yellow tag. But he assured me (sarcastically), he will put the Ham in the
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 5 of 25
`
`Page 5 of 13
`
`refrigerator at his office, and when "Tim" (assumed the Regional manager) come in the
`afternoon, he will show it to him, and get an explanation.
`
`Gentlemen & Ladies, 2 days later, I visited again the Store and the same exactly Ham, same
`tag, was again at the store shelves, along with another hundreds similar products overcharged
`up to 200%. ( and it was just a neighborhood Store).
`
`I bought it again and ( recorder the procedure). Unfortunately, the photos of all overcharged
`products (like this) added to the amended complaint, never entered as evidences in the docket,
`so everybody could understand, that the $1.67 that the attorneys agreed as Averaee
`Overchaa:;e, it's a convenient myth. Not reality. Let's do 1st grade math.
`
`The max.settlement amount is $ 9.5 million. If Walmart in US. runs 5000+ stores, and
`multiply by 5 (year's class action period), times 365 days = 9.5 million. So if we divide this
`number by $1.67 - the celling settlement amount, (minus 3 million for attorney+ expenses)
`covers less than a half overcharged item per dav, per each store.
`
`dare to call the settlement fair, reasonable, and adequate?
`
`Are they serious? They
`
`How about the third component of the Settlement. Is for those Class Members who purchased
`Weighted Goods during the Class Period, retained proofs of purchase or other documentation
`AND retained proof of the packaging to demonstrate the amount of overpayment!!!
`
`"This benefit (attorneys insist) is crucial because it permits Settlement Class Members to
`recover all amounts, they were overcharged during the Class Period". Another insult to
`victim's intelligence, if they insist that (besides me) consumers the last 5 years kept the
`dirty& stinky full of bacteria packaging of meat and fish, just in case one day they ll need
`it!!!
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 6 of 25
`
`At Walmart's Restrooms, mainly at stores located in low income areas, there are plenty of
`sighs with the follow threats.
`
`Page 6 of 13
`
`"Shoplifting is stealing, and shoplifters apprehended. Even if it's their first offence will
`punished with a lengthy prison term and a substantial monetary fine, plus a record will haunt
`them for the rest of your life".
`
`Of course, is in English and Spanish only, since everybody knows that French or Italian or
`Greek speaking customers they don't steal.
`
`But if shoplifting is stealing, "customer lifting" or overcharging, or gouge, or Rip off ( and
`all other synonyms), shouldn't punished in a similar way?
`
`Why when the store gets caught red hand, and you (the customer) have a proof to demonstrate
`the amount of (systematically) overcharged, at best case scenario you get only the difference,
`without any consequence for the store. Why states like Michigan have the "Michigan's
`Scanner Law" where, the seller will refund you the difference between the amount charged
`and the price displayed, plus a "bonus" of ten times the difference.
`
`Or in Canada (since we have a lot of snow birds, and they will never be compensated fairly
`with this settlement ), "if the scanned price of an item is higher than the price shown on the
`shelve or advertised by the store, for instance, the customer is entitled to receive any item $10
`or less for free. Why our legislators care only for the seller's interests and created the 812.015
`anti-theft law to be applied only to customers. "Violators may receive a penalty of monetary
`fines, jail or prison time, and/or the suspension of your driver's license even for a piece of gum.
`
`"Altering or removing a label, universal product code (UPC), or price tag also falls under
`the definition". But is it what exactly Walmart doing, when manipulate the UPC (bar)code, in
`order to overcharge?
`
`If not (its 2nd grade math) please explain that next photo (after you enlarge it).
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 7 of 25
`
`Page 7 of 13
`
`~=-·=-:=<I
`-
`
`s.~s
`-f. 6. 16 _ _..,.
`=10 1
`,--~ -
`5.t4 x 1~5~
`,Joi~ 6:1&
`
`You solved the puzzle?
`
`In paragraph #38 Plaintiff's counsel (on my behalf L.O.L.) explains that for the "benefits"
`provided under the settlement, class members/victims will release any legal claims that
`may arise from OR RELATE to the facts and claims ALLEGED in the complaint.
`
`In your opinion Sirs these resent photos (you will find in the included USB thumb drive) with
`this new and improved way to scam the customers), is related to the original ''trick Walmart
`used to deceive customers advertising with low but FAKE price per unit.?
`
`"Members will release ariy legal claims that may arise from or relate to the facts alleged in the
`Second Amended Complaint ".
`
`This is the main reason Your Honor I declined the Service Award. As the plaintiffs' attorneys
`are fully aware, Walmart use more than few ways to scam people, even for the specific
`category of the weighted products, other than the reduced with fake low price per unit.
`
`While in the settlement WALMART promising to take measures to eliminate such practices,
`up to this moment, I know for a fact that never stopped. May reduced the initial method a bit,
`but in the same time increased similar methods even more aggressively, ruthlessly and
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 8 of 25
`
`Page 8 of 13
`
`diabolically. You see, is the only Supermarket grocery chain, that at the end of the day has so
`many "about to expire" products. People believing that getting a bargain, and take the bait. In
`reality, many times (and recently) when I bought marked as REDUSED products, not only I
`overcharged, but on top were EXPIRED! Even baby food formulas which had expired more
`than a year. At cash register I paid more than the yellow tag indicated, and when I returned it
`and informed the employees that are expired and dangerous, the next week were again on the
`selves (see incl. photo-copies).
`
`Walmart argues in the 1st motion to dismiss, that these allegations do not establish that the unit
`price mistakes were not isolated errors or that the mistakes did not result from a faulty labeling
`machine, computer glitch, or human error.
`
`Watch what you wish for. Should a faulty labeling machine, or a computer glitch justify that the
`last 3 years I discovered and "collected" from hundreds of stores, thousands of visits, more than
`2 terabytes of data consisted of tens of thousands photos, videos, scanned receipts , and even
`more than 70,000 back up color hard-copies of evidences?
`
`Could considered as an isolated error when, simultaneously stores at west east north and south
`of Florida, for months selling the same products with manipulated prices, even when numerous
`times I complained to managers, who agreed/admitted were wrong, agreed to corrected, but
`nothing change because, everything handled from Arkansas main office, and most of the
`times nothing they can do about it?
`
`Last year I worked in my job double shifts up to 80 hours a week in order to cover this quest
`expenses. And I have been not only ripped off by Walmart, but also insulted, humiliated, cyber
`and physical attacked, threatened, and kicked out when I dare to complain.
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 9 of 25
`
`Page 9 of 13
`
`Walmart called the class action "this far-reaching suit''. Also claims Plaintiff does not even
`come close to satisfying X ... Rule 9. "The Complaint contains no specific factual allegations
`as to the "who, what, when, where, and how" of Walmart s alleged Pricing Practice. "
`
`I understand that you are expecting supporting evidences for all these, "allegations" and
`fortunately, an ex-investigating reporter like me, also use as a guide
`the ''who, what, when,
`where, and how" procedures. So, at the end of this letter of objection you will find a link to a
`IS-minute YouTube video. I urged to whoever wish to watch, to use the pause button very
`often, and you will be surprised (not necessary pleasantly) from this tiny visual sample. The
`percentage stolen from customers, it's not just double the profit margin. Much more. When,
`for example (at 12min 43 sec.) a lobster at shelve tag shows $20 per/Lb. and at the register you
`if served at a
`fancy
`seafood
`charged $38 you
`realized
`that would cost
`less
`restaurant.
`
`But the defendant claims that the misrepresentations were so subtle that Plaintiff and other
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 10 of 25
`
`reasoflable consumers failed to notice until a closer inspection was made.
`
`Well WALMART should keep that in mind when I will produce "malpresentations of 1500%.
`Kindly request to please listen CAREFULLY at the end of the video -where a Customer
`Service Manager (to whom I complained) when I insisted why the price is wrong-, her
`respond ...
`
`Page 10 of 13
`
`"HI said why the prices are wrong, I may lose my job"!
`
`www.yolllllbe.com/wald,?v=i9x7Axwm1Lc&feature=emb logo
`
`And last but not least please watch again and again, the price scanner monitors how magically
`instead to read (and charge) the reduced price, shows (and you will pay) the WAS/original.
`
`This video link sent, along with 80 pages of hard evidences/ samples of Walmart's various
`methods of deception and fraudulent over-charges-gouging (included illegal taxation for
`nontaxable items) at stores and online, by MAIL last May, at certain AG Offices, including
`Florida's (who took them 2 months to acknowledge that received), It would take 10 minutes for
`an inspector to visit any Walmart store, purchase the specific products and verify -beyond
`reasonable doubt- the scams which systematically -special during the pandemic- ripping off
`customers. But amazingly nobody dared or bothered to lift a finger. Until one day America see
`it on the News or Social Media, this multi billions dollars scandal will continue to embarrass
`overnment states and cities the so called "CONSUMER PROTECTION AGENCIES".
`
`APPU FIITTTER 6 er
`
`$ 2.97
`
`Walmart sought to have the case dismissed, arguing that Mr. Kukorinis (the plaintiff) was not
`deceived by its pricing practices because, even after he claimed to have noticed the pricing
`discrepancies, he "continued purchasing weighted goods with inco"ect unit prices," and
`willingly paid the price displayed on the packages (They call me masochist?).
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 11 of 25
`
`Page 11 of 13
`
`Thankfully Judge J. MARTINEZ rejected Walmart's argument. 'Contrary to Walmart s
`as.5ertion, ' he ruled, "the fact that Plaintiff continued to purchase weighted goods does
`not negate his injury but may in fact highlight the pervasive effect of the aUeged
`misconducL"' Thank you, your Honor.
`
`Once the Judge ruled that the case could proceed - Walmart and Plaintiffs' counsel (behind his
`back) quickly decided to settle. Allegedly, according to Mr Janchunis he "carefully weighted
`with me - who I was present for the November 2019 1st mediation (true but nothing then
`agreed)," AND available ! ! ! throughout the March 2020 2•d mediation session, where the
`parties hard-fought at arm's len~ (but VIRTUALY).
`
`And that it's NOT TRUE. Since January and up to this day nobody updated me talk, text or
`e-mail me about the case.
`
`And now I am learning from websites that "The costs, risks, and delay of trial and appeal
`weigh in favor of settlement approval" !!!
`
`So The Plaintiff started by A)"accusing Defendant "WALMART actions constitute
`unconscionable, deceptive, or unfair acts or practices because, as alleged herein, Defendant
`advertised, marketed, and sold the Weighted Goods at one value but charged consumers a
`higher value at checkout, thereby offending an established public policy, and engaging in
`immoral, unethical, oppressive, and unscrupulous activities that are and were substantially
`injurious to consumers" ... Plaintiff hereby demands trial by jury of claims in this Amended
`Class Action Complaint.
`
`And ended-thanks to successful negotiations- scot free, so DECLARES that B)"Walmart
`does not concede the Plaintiff's allegations, nor does it concede all of the factual
`statements set forth herein. For purposes of this Settlement, however, Walmart does not
`oppose
`the
`filing
`of
`this
`Motion
`for
`Preliminary
`A roval."
`
`So why FTC requires that any retailer who offers price comparisons "should make certain
`that the bargain off er is genuine and truthful, and not contain any deceptive or unfair
`aspect. What about the words of Wal-Mart founder Sam Walton, who built Wal.mart?
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 12 of 25
`
`Page 12 of 13
`
`"Personal and moral integrity is one of our basic fundamentals, and it has to start with
`each of us." "Don't compromise your reputation. It's a precious commodity. Don't
`compromise your integrity ... have a good name."
`
`I guess current CEO should add "The devil is in the details. Toe winner takes it all, the loser
`standing small. Speaking of details please enlarge these photos from the Walmart's site
`www.iet.com which recently "absorbed" by www.walmart.com and get a taste of how their
`"creative math" stolen from its online customers billion by overcharging them up to 1500%
`
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`
`In conclusion.
`
`I, Vassilios Kukorinis known as ''Plaintiff' I declare under penalty of perjury that all the above
`is true and correct. I do not oppose this motion for preliminary approval of the settlement, and
`whatever terms the attorneys of both parties agreed, with exceptions:
`
`

`

`' .
`
`'
`
`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 13 of 25
`
`Page 13 of 13
`
`1) Plaintiff not to receive the suggested AWARD PRICE OF$ 25,000.00
`
`2) Understanding that Members of the Class in order to receive the "benefits" provided
`under the settlement, will have to release any legal claims that may arise but, ONLY for the
`facts alleged in the Second Amended Complaint. Not FACTS for related, like the photo
`examples.
`
`3) If it's not mandatory, I do not wish to be present at Court on 21 st of February 2021.
`
`Thank you all for your times and efforts. -
`
`Vassilios Kukorinis
`
`2524 W. De Leon Street
`
`Tampa, FL 33609.
`
`e-mail: Vaskuko@gmail.com
`
`Tel: 347-837 1918
`
`

`

`\
`
`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 14 of 25
`
`ATLANTIC
`SALMON
`){:=~:>
`
`

`

`Case 1:19-cv-20592-JEM Document 43 Entered on FLSD Docket 09/25/2020 Page 15 of 25
`
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