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., 5 FILED BY Fr; D.C. SEP 25 2020 Page 1 of 13 ANGELA E. NOBLE 09/22/2020

CLERK U.S. DIST. CT. VASSILIOS KUKORINIS V WALMART, INC. S. 0. Of FLA.·
MIAMI CASE 1: 19-cv-20592-JEM -MARTINEZ/OTAZO- 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. 5 Page 2 of 13 When MORGAN & MORGAN
drafted the initial complaint, I protested to the attorneys by e- 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 18thâ ¢ 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 5 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 NAVY 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. 5 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, Plaintiffpurchased 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- 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 5 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. Are they serious?
They dare to call the settlement fair, reasonable, and adequate? How about the third
component of the Settlement. Is for those Class Members who purchased Weighted
Goods during the Class Period, retained proofs ofpurchase 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!!! 5 Page 6 of 13 At Walmart's Restrooms, mainly at
stores located in low income areas, there are plenty of sighs with the follow threats.
"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 ofyour 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). 5 Page 7 of 13 ~=-·=-:=<I -f. 6.s.~s16 _ _..,. - =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 5 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. 5 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
charged $38 you realized that would cost less if served at a fancy seafood
restaurant. But the defendant claims that the misrepresentations were so subtle that
Plaintiffand other 5 Page 10 of 13 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 ... "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?). 5 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 ofthe 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 2â ¢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 offer 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? 5 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% lMabar Coconut Cream Pie HUit & Nut - ---..a:,...._._...,.......~ ..... - --
-.u....... C--..a..JllieFllill~ ..... - U....,.,._..c.tiallt'Dill...,... Ban, U oz. 16 count 8 - - &.:mt.
-101..--,q ..... ⠢p-,. ~ - C - - t vet ee ⠢⠢ _____: 0::,, ⠢⠢ -2--,-:.: -=--
ill!II,.,._ - ---- ⠢ 0 .. ., ⠢ = -Q_..,___ ⠢ -- ⠢⠢ -c. i - ⠢ --...- 0 -- ⠢ --
...,_-â -.a- S-..'P C ......._, CJRnlll.tUAOl..â ¢ct. . .d4 â ¢ Uptcn lced Tea, Peach,
16.9 R Oz ⠢ - -- ⠢ --·- - ⠢ -: .. 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: ' ' . 5 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-
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