Villarroel

I. BACKGROUND

21 Plaintiffs’ claims arise from Recology’s alleged bribery of Mohammed Nuru—the former 22 Director of the San Francisco Department of Public Works—to “obtain improper garbage 23 collection rate increases from the City and County of San Francisco.” Dkt. No. 1, Ex. Z (“TAC”) 24 ¶ 1. 25 On November 28, 2020, Paul Giusti—a former Recology executive—was criminally 26 indicted by the United States Attorney’s Office after a joint FBI and IRS taskforce “determined [] 27 there [was] probable cause to believe that Giusti bribed Mohammed Nuru . . . .” Id. ¶ 29. On July 28, 2021, Mr. Giusti pled guilty to conspiracy to bribe a local official and commit honest services fraud. Id. ¶ 122. On March 4, 2021, the City Attorney of San Francisco sued Recology for alleged violations of the City of San Francisco’s (the “City”) campaign and governmental conduct code and California’s Unfair Competition Law (UCL). Mot. at 12. The case settled, and Recology agreed to “make restitution . . . to [r]atepayers for the full amount of the difference between the rate increases . . . that took effect July 1, 2017, and subsequent rate increases through March…