Plaintiff demanded penalties based on a blanket assumption of 100% violation rates across all violation categories for all employees in all pay periods. The exposure model I constructed challenged each assumption independently: initial violations carry a $100 penalty while subsequent violations carry $200, but the plaintiff's demand applied the subsequent rate to every pay period. Job-classification-specific analysis revealed that certain categories — particularly meal period claims — affected only a subset of the workforce (drivers on specific routes, not dispatchers or administrative staff). The supporting declaration addressed the factual basis for each violation rate reduction, incorporating time record analysis and route-scheduling data. The mediator — a former plaintiff's wage-and-hour attorney — described the declarations as among the strongest he had reviewed in his career. Plaintiff's counsel acknowledged the analysis materially reduced their settlement demand.