Patrick D. Toole represented Plaintiffs in a class action against employer Pacific Gas and Electric Company and union, alleging that employer failed to pay wages due under a collective bargaining agreement (“CBA”), and that the union breached its duty of fair representation. This case resulted in no less than three significant opinions. First, Plaintiffs established they were not required to exhaust a grievance process before bringing a Labor Management Relations Act (“LMRA”) claim; second, Plaintiffs established precedent preventing witnesses from materially altering their deposition testimony to support a summary judgment motion; and third, genuine issues of material fact existed on the question of whether the union conducted an adequate investigation prior to entering into settlement agreements with PG&E. These rulings ultimately led to a $5.8 million settlement in favor of the firm’s clients.