This is an agreement between (“the Client”) and the law firms of Abraham Watkins and Andrew J. Cobos (“the Attorneys”), all collectively referred to as “the Parties.”  The Parties agree to the following:

1. PURPOSE OF CONTRACT:

The Client employs the Attorneys to prosecute all the Client’s claims against the 3M Company or its affiliates regarding defectively designed earplugs that resulted in Client’s tinnitus and/or hearing loss (the “Claims”).  The Client understands that this contract for legal services is for representation on those Claims alone, and that the primary purpose of this representation is to obtain the highest available monetary recovery for Client with respect to such Claims.

2. ATTORNEYS’ FEES:

     2.01. The Attorneys will be financially compensated by the Client ONLY if a recovery is made.  Attorneys’ fees will be calculated based on the amount of the recovery. The Client does hereby assign and convey to the Attorneys a 40% undivided interest in the gross value of any settlement or recovery.  The Client shall not be responsible for any attorney’s fees if no recovery is made.

     2.02. The term “the gross value of any recovery” as used above regarding the percentage to be paid to Attorneys means the present value of all monies recovered for Client.

3. APPROVAL NECESSARY FOR SETTLEMENT

     3.01. Client grants to the Attorneys a power of attorney to handle negotiations and settlement discussions regarding Client's legal matter.  This limited power of attorney further authorizes the Attorneys to make payments to parties other than Client and Attorneys for their services performed, fees charged, or bills rendered in connection with representing Client.  This expressly includes the right to sign Client's name on and to any insurance company drafts, money orders, cashier's checks, checks or other negotiable instruments made payable to both the Attorneys and Client.

     3.02. No settlement shall be made without Client's prior approval. Prior to reaching a settlement, Attorneys shall fully disclose to Client the amount Client will receive, as well as a breakdown of Attorneys’ fees and case expenses. Client shall not seek or obtain any settlement on the Claims without the Attorneys’ advice and counsel.

     3.03. Client grants to the Attorneys a power of attorney to prepare, sign and file all legal instruments, pleadings, drafts, authorizations and papers as shall be reasonably necessary to prosecute and or conclude this representation.

4. EXPENSES:

Attorneys shall advance funds necessary to cover costs and reasonable expenses for prosecution of the claims.  Expenses of litigation include, but are not limited to, court costs, deposition and mediation costs, expert witnesses, meetings, travel, investigation expenses, medical record retrieval, reproduction, communication, postage, and delivery expenses.  Client agrees to pay all expenses incurred by the Attorneys on behalf of the Client from the Client’s share of the recovery at the conclusion of the litigation.  If no recovery is made, no expense payment shall be due to the Attorneys by the Client.

5. OBLIGATION OF PARTIES:

     5.01  The Client shall keep the Attorneys advised of his current address and telephone numbers at all times, shall appear on reasonable notice at any and all depositions and court appearances, and shall comply with all reasonable requests from the Attorneys in connection with the preparation of the Client’s Claim.

     5.02  The Attorneys shall provide the Client with competent representation, which requires legal knowledge, skill, thoroughness, and preparation to handle the matters set forth in this agreement. Once employed, the Attorneys will act with reasonable diligence and promptness, as well as use their best efforts on behalf of the Client. The Attorneys shall further keep the Client reasonably informed about the status of the representation and will promptly respond to reasonable requests for information, including any reasonable request for an estimate of present and/or future costs and expenses of the representation or an appropriate portion thereof.

6. SUBROGATION AND LIENS:

Repayment to third parties that paid the Client’s medical expenses may be required by contract or statute.  Such payment obligations shall be the Client’s responsibility and shall be paid out of the Client’s settlement proceeds.

7. ASSOCIATION OF OTHER ATTORNEYS OR SERVICES:

Attorneys may associate with other Attorneys to assist in the representation of the aforesaid claims of the Client, provided that such association will not increase the Attorneys’ fees.

8. REPRESENTATIONS:

It is understood and agreed that Attorneys do not warrant or guarantee the outcome of the Claims, and Attorneys have not represented to the Client any amount of recovery.  Attorneys further make no representations regarding the tax effects of any recovery.

9. PERMISSION TO WITHDRAW:

The Attorneys may, at their option, withdraw from the case for any reason.  In the event of a withdrawal, the Attorneys shall notify the Client in writing.  In the event the Attorneys exercise their right to withdraw, the Client shall not owe the Attorneys any attorney fees, unless withdrawal is the result of Client’s failure to cooperate with the prosecution of the Claim.  If the Client discharges the Attorneys, Attorneys are entitled to full attorneys’ fees, expenses, loans and interest thereon, as set forth in this contract, unless such discharge is for good cause.

10. RESOLUTION OF DISPUTES / ARBITRATION:

Any and all disputes, controversies, claims or demands arising out of or relating to this Agreement or concerning the services by Attorneys to Client shall be resolved by binding arbitration pursuant to the rules of the American Arbitration Association.  Any such arbitration proceeding shall be conducted in Harris County, Texas before three arbitrators.  

11. LEGAL CONSTRUCTION:

If any provision contained in this Agreement shall for any reason be held to be unenforceable, such provision shall not affect any other provision within this Agreement.

15. AWARE OF TERMS

I certify and acknowledge that I have had the opportunity to read this Agreement. I further state that I have voluntarily entered into this Agreement fully aware of its terms and conditions.

SIGNED and AGREED to on this day: April 24, 2024.


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Client’s Signature:                                                                ON BEHALF OF ANDREW J. COBOS:

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Signed by Andrew J. Cobos
Signed On: March 5, 2024

Signature Certificate

Document name: Power of Attorney & Contract of Employment (T5)

Unique Document ID: 8086d841411b77900d86b57f91df5523e35b0060

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Timestamp	Audit
January 20, 2019 2:28 am EDT	Power of Attorney & Contract of Employment (T5) Uploaded by Andrew J. Cobos - counsel@militaryearplug.com IP 72.106.81.139
January 20, 2019 3:29 am EDT	Susan Gonzales - sgonzales@silentprofessionals.org added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 3:32 am EDT	Susan Gonzales - sgonzales@silentprofessionals.org added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 3:34 am EDT	Susan Gonzales - sgonzales@silentprofessionals.org added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 3:37 am EDT	Susan Gonzales - sgonzales@silentprofessionals.org added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 3:44 am EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 3:51 am EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 9:00 am EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 9:05 am EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 3:10 pm EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 20, 2019 3:12 pm EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - sgonzales@silentprofessionals.org as a CC'd Recipient Ip: 162.197.195.39
January 21, 2019 9:50 am EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - counsel@militaryearplug.com as a CC'd Recipient Ip: 162.197.195.39
January 21, 2019 8:44 pm EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - counsel@militaryearplug.com as a CC'd Recipient Ip: 162.197.195.39
January 22, 2019 5:47 pm EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - counsel@militaryearplug.com as a CC'd Recipient Ip: 162.197.195.39
January 22, 2019 5:52 pm EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - counsel@militaryearplug.com as a CC'd Recipient Ip: 162.197.195.39
January 22, 2019 5:53 pm EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - counsel@militaryearplug.com as a CC'd Recipient Ip: 162.197.195.39
January 22, 2019 6:02 pm EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - counsel@militaryearplug.com as a CC'd Recipient Ip: 162.197.195.39
January 22, 2019 6:10 pm EDT	Susan Gonzales - susan@node-marketing.com added by Andrew J. Cobos - counsel@militaryearplug.com as a CC'd Recipient Ip: 162.197.195.39

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https://militaryearplug.com/

Audit Trail Serial# b2f8b0a5434a7f8634674e6477e39f0b