On December 20, 2018 a
Miscellaneous
was filed
involving a dispute between
Hurns, Laquita,
and
Tradenet Enterprises, Inc., A California Corporation,
Vantage Led, Llc,
for Employment - Complex
in the District Court of San Bernardino County.
Preview
r
j
CM 010
Bar number and add2ss FOR COURT USE ONlY
ATTORNEY OR PARTY WITHOUTATTORNEY Name Stale
PROTECTION LAW tiROUP LLf
Amir Nayebdadash SBN 232204 Heather Davis SBN 239372
I 36 Main Street Suite A
El Segundo California 90245
SUPERIpR COU T OF CuqUFOf NIA
TELEPHONE NO 4124 29r0 3095 Fnx No 866 264 7880 COUNTY
SAN OF SAN BERNARDINO
BERNARDiNO
I
ATTORNEY FOR Name ialIltlfl Laquita Hurns CIVIL DIVISION
SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO
2L
C O p
STREETADDRESS 7 IeSt Z 1 lyd treet
MAILINGADDRESS 7
CITYANDZIPCODE S n Bel 1 Y d I 9241S O210 V L y
k
BRANc NAME San Bernardino Justice Center NI A Q
CASE NAME
Laquita Hurns v Vantage LED LLC et al
CASE NUMBER
CIVIL CASE COVER SHEET Com P lex Case Desi 9 nation h vy
0 Unlimited 0 Limited
Amount
0 Counter 0 Joinder
Amount UDGE
demanded demanded is Filed with first appearance by defendant
exceeds 25 000 25 000 or less Cal Rules of Court rule 3 402 DEPT
Items 1 6 below must be completed see instructions on page 2
1 Check one box below for the case type that best describes this case
Auto Tort Contract Provisionally Complex Civil Litigation
06 Cal Rules of Court rules 3 400 3 403
Auto 22 Breach of contracUwarranty
0 Uninsured motorist 46 Rule 3 740 collections 09 AntitrusUTrade regulation 03
Other PI PD VUD Personal Injury Property Other collections 09 0 Construction defect 10
Damage Wrongful Death Tort Insurance coverage 18 0 Mass tort 40
Asbestos 04
Other contract 37 0 Securities litigation 28
Product liability 24 Real Environmental Toxic tort 30
Property
Medical malpractice 45 Eminent domain Inverse Insurance coverage claims arising from the
14 above listed provisionally complex case
0 condemnation
Other PI PD WD 23
types 41
Non PI PD VVD Other Tort 0 Nrongful eviction 33
Business tort unfair business practice 07 0 Other real
property 26 Enforcement of Judgment
Uniawful Detainer Enforcement of judgment 20
Civil rights 08
Defamation 13 0 Commercial 31 Miscellaneous Civil Complaint
Fraud 16 0 Residential 32 RICO 27
0 Intellectual property 19 Drugs 38
0 Other complaint not specified above 42
Professional negligence 25 Judicial Review
Miscellaneous Civil Petition
Other non PI PD WD tort 35 0 Asset forfeiture 05 partnership and corporate governance 21
Employment 0 Petition re arbitration award 11 Other petition not specified above 43
0 Wrongful termination 36 0 Writ of mandate 02
Other employment 15 0 Other judicial review 39
2 This case is is not complex under rule 3 400 of the California Rules of Court If the case is complex mark the
factors requiring exceptional judicial management
a 0 Large number of separately represented parties d 0 Large number of witnesses
b Extensive motion practice raising difficult or novel e 0 Coordination with related actions pending in one or more courts
issues that will be time consuming to resolve in other counties states or countries or in a federal court
c Substantial amount of documentary evidence f 0 Substantial postjudgment judicial supervision
3 Remedies sought check all that apply a monetary b
nonmonetary declaratory or injunctive relief c 0 punitive
4 Number of causes of action specify Ten 10
5 This case Q is Q is not a class action suit
6 If there are any known related cases file and serve a notice of related case You may use form CM 015
ate December 20 2018
Y
Heather Davis
TYPE OR PRINT NAME SIGNATURE OF PARTY OR ATTORNEY FOR PARTY
NOTICE
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding except small claims cases or cases filed
under the Probate Code Family Code or Welfare and Institutions Code Cal Rules of Court rule 3220 Failure to file may result
in sanctions
File this cover sheet in addition to any cover sheet required by local court rule
If this case is complex under rule 3 400 et seq of the California Rules of Court you must serve a copy of this cover sheet on all
other parties to the action or proceeding
Unless this is a collections case under rule 3 740 or a complex case this cover sheet will be used for statistical purposes onl r
age 1 of 2
Cal RulesofCourLrules2 30 3220 3 40a3 403 3J40
CIVIL CASE COVER SHEET
FormAdoptedforMantlatoryUse
Judicial Council ofCalifornia Cal Standards of Judiaal Adminishation std 3 10
www courtinfo ca gov
CM 010 Rev L 2007
July
C M 010
INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
To Plaintiffs and Others Filing First Papers If you are filing a first paper for example a complaint in a civil case you must
complete and file along with your first paper the Civil Case Cover Sheet contained on page 1 This information will be used to compile
statistics about the types and numbers of cases filed You must complete items 1 through 6 on the sheet In item 1 you must check
one box for the case type that best describes the case If the case fits both a general and a more specific type of case listed in item 1
check the more specific one If the case has multiple causes of action check the box that best indicates the primary cause of action
To assist you in completing the sheet examples of the cases that belong under each case type in item 1 are provided below A cover
sheet must be filed only with your initial paper Failure to file a cover sheet with the first paper filed in a civil case may subject a party
its counsel or both to sanctions under rules 2 30 and 3 220 of the California Rules of Court
To Parties in Rule 3 740 Collections Cases A collections case under rule 3 740 is defined as an action for recovery of money
owed in a sum stated to be certain that is not more than 25 000 exclusive of interest and attorney s fees arising from a transaction in
which property services or money was acquired on credit A collections case does not include an action seeking the following 1 tort
damages 2 punitive damages 3 recovery of real property 4 recovery of personal property or 5 a prejudgment writ of
attachment The identification of a case as a rule 3 740 collections case on this form means that it will be exempt from the general
time for service requirements and case management rules unless a defendant files a responsive pleading A rule 3 740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3 740
To Parties in Complex Cases In complex cases only parties must also use the Civil Case Cover Sheet to designate whether the
case is complex If a plaintiff believes the case is complex under rule 3 400 of the California Rules of Court this must be indicated by
completing the appropriate boxes in items 1 and 2 If a plaintiff designates a case as complex the cover sheet must be served with the
complaint on all parties to the action A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiffs designation a counter designation that the case is not complex or if the plaintiff has made no designation a designation that
the CaSe iS Complex
CASE TYPES AND EXAMPLES
Auto Tort Contract Provisionally Complex Civil Litigation Cal
Auto 22 Personal Injury Property Breach of Contract Warranty 06 Rules of Court Rules 3 400 3 403
Damage Wrongful Death Breach of Rental Lease Antitrust Trade Regulation 03
Uninsured Motorist 46 if the Contract not unlawful detainer Construction Defect 10
case involves an uninsured or wrongful eviction Claims Involving Mass Tort 40
motorist claim subject to ContracUWarranty Breach Seller Securities Litigation 28
arbitration check this item Plaintiff not fraud ornegligence Environmental Toxic Tort 30
instead of Auto Negligent Breach of ContracU Insurance Coverage Claims
Other PI PD WD Personal lnjury Warranty arising from provisionally complex
Other Breach of
ContracUWarranty case type listed above 41
Property Damage Wrongful Death
Tort Collections e
money g owed open Enforcement of Judgment
Asbestos 04 book accounts 09 Enforcement of Judgment 20
Asbestos Collection Case Seller Plaintiff Abstract of Judgment Out of
Property Damage
Asbestos Personal Injury Other Promissory Note Collections County
Wrongful Death Case Confession of Judgment non
Insurance Coverage not
provisionally domestic relations
Product Liability not asbestos or
complex 18 Sister State Judgment
toxic nvironmental 24
Medical Malpractice 45 Auto Subrogation Administrative Agency Award
Medical Malpractice Other Coverage not unpaid taxes
Physicians Surgeons Other Contract 37 Petition Certification of Entry of
Other Professional Health Care Contractual Fraud Judgment on Unpaid Taxes
Malpractice Other Contract Dispute Other Enforcement of Judgment
Case
Other PI PD WD 23 Real Property
Premises Eminent Domain Inverse Miscellaneous Civil Complaint
Liability e g slip
Condemnation RICO 27
and fall 14
Intentional Bodily Injury PDlWD Wrongful Eviction 33 Other Complaint not specified
e above 42
g assault vandalism Other Real Property e g quiet title 26
Intentional Infliction of Writ of Possession of Real Property Declaratory Relief Only
Emotional Distress Mortgage Foreclosure
Injunctive Relief Only non
Negligent Infliction of
harassment
Quiet Title
Emotional Distress Mechanics Lien
Other Real Property not eminent
Other PI PD WD domain Other Commercial Complaint
landlord tenant or
Non PI PD WD Other Tort Case non tort non complex
foreclosure
Other Civil Complaint
Business Tort Unfair Business Unlawful Detainer
non tort non complex
Practice 07 Commercial 31
Miscellaneous Civil Petition
Civil Rights e g discrimination Residential 32
false Partnership and Corporate
arrest not civil Drugs 38 if the case involves illegal Governance 21
harassment 08 drugs check this item otherwise
Defamation Other Petition not specified
e g slander libel report as Commercial or Residential
above 43
13 Judicial Review
Civil Harassment
Fraud 16 Asset Forfeiture 05
Workplace Violence
Intellectual Property 19 Petition Re Arbitration Award 11
Elder Dependent Adult
Professional Negligence 25 Writ of Mandate 02
Abuse
Legal Malpractice Writ Administrative Mandamus
Election Contest
Other Professional Malpractice Writ Mandamus on Limited Court
Petition for Name Change
not medical or legal Case Matter
Petition for Relief From Late
Other Non PI PD WD Tort 35 Writ Other Limited Court Case Claim
Employment
Review Other Civil Petition
Wrongful Termination 36
Other Judicial Review 39
Other Employment 15
Review of Heaith O cer Order
Notice of Appeal Labor
Commissioner Appeals
CM 010 Rev July L 2007 Page 2 of 2
CIVIL CASE COVER SHEET
Document Filed Date
December 20, 2018
Case Filing Date
December 20, 2018
Category
Employment - Complex
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r j CM 010 Bar number and add2ss FOR COURT USE ONlY ATTORNEY OR PARTY WITHOUTATTORNEY Name Stale PROTECTION LAW tiROUP LLf Amir Nayebdadash SBN 232204 Heather Davis SBN 239372 I 36 Main Street Suite A El Segundo California 90245 SUPERIpR COU T OF CuqUFOf NIA TELEPHONE NO 4124 29r0 3095 Fnx No 866 264 7880 COUNTY SAN OF SAN BERNARDINO BERNARDiNO I ATTORNEY FOR Name ialIltlfl Laquita Hurns CIVIL DIVISION SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO 2L C O p STREETADDRESS 7 IeSt Z 1 lyd treet MAILINGADDRESS 7 CITYANDZIPCODE S n Bel 1 Y d I 9241S O210 V L y k BRANc NAME San Bernardino Justice Center NI A Q CASE NAME Laquita Hurns v Vantage LED LLC et al CASE NUMBER CIVIL CASE COVER SHEET Com P lex Case Desi 9 nation h vy 0 Unlimited 0 Limited Amount 0 Counter 0 Joinder Amount UDGE demanded demanded is Filed with first appearance by defendant exceeds 25 000 25 000 or less Cal Rules of Court rule 3 402 DEPT Items 1 6 below must be completed see instructions on page 2 1 Check one box below for the case type that best describes this case Auto Tort Contract Provisionally Complex Civil Litigation 06 Cal Rules of Court rules 3 400 3 403 Auto 22 Breach of contracUwarranty 0 Uninsured motorist 46 Rule 3 740 collections 09 AntitrusUTrade regulation 03 Other PI PD VUD Personal Injury Property Other collections 09 0 Construction defect 10 Damage Wrongful Death Tort Insurance coverage 18 0 Mass tort 40 Asbestos 04 Other contract 37 0 Securities litigation 28 Product liability 24 Real Environmental Toxic tort 30 Property Medical malpractice 45 Eminent domain Inverse Insurance coverage claims arising from the 14 above listed provisionally complex case 0 condemnation Other PI PD WD 23 types 41 Non PI PD VVD Other Tort 0 Nrongful eviction 33 Business tort unfair business practice 07 0 Other real property 26 Enforcement of Judgment Uniawful Detainer Enforcement of judgment 20 Civil rights 08 Defamation 13 0 Commercial 31 Miscellaneous Civil Complaint Fraud 16 0 Residential 32 RICO 27 0 Intellectual property 19 Drugs 38 0 Other complaint not specified above 42 Professional negligence 25 Judicial Review Miscellaneous Civil Petition Other non PI PD WD tort 35 0 Asset forfeiture 05 partnership and corporate governance 21 Employment 0 Petition re arbitration award 11 Other petition not specified above 43 0 Wrongful termination 36 0 Writ of mandate 02 Other employment 15 0 Other judicial review 39 2 This case is is not complex under rule 3 400 of the California Rules of Court If the case is complex mark the factors requiring exceptional judicial management a 0 Large number of separately represented parties d 0 Large number of witnesses b Extensive motion practice raising difficult or novel e 0 Coordination with related actions pending in one or more courts issues that will be time consuming to resolve in other counties states or countries or in a federal court c Substantial amount of documentary evidence f 0 Substantial postjudgment judicial supervision 3 Remedies sought check all that apply a monetary b nonmonetary declaratory or injunctive relief c 0 punitive 4 Number of causes of action specify Ten 10 5 This case Q is Q is not a class action suit 6 If there are any known related cases file and serve a notice of related case You may use form CM 015 ate December 20 2018 Y Heather Davis TYPE OR PRINT NAME SIGNATURE OF PARTY OR ATTORNEY FOR PARTY NOTICE Plaintiff must file this cover sheet with the first paper filed in the action or proceeding except small claims cases or cases filed under the Probate Code Family Code or Welfare and Institutions Code Cal Rules of Court rule 3220 Failure to file may result in sanctions File this cover sheet in addition to any cover sheet required by local court rule If this case is complex under rule 3 400 et seq of the California Rules of Court you must serve a copy of this cover sheet on all other parties to the action or proceeding Unless this is a collections case under rule 3 740 or a complex case this cover sheet will be used for statistical purposes onl r age 1 of 2 Cal RulesofCourLrules2 30 3220 3 40a3 403 3J40 CIVIL CASE COVER SHEET FormAdoptedforMantlatoryUse Judicial Council ofCalifornia Cal Standards of Judiaal Adminishation std 3 10 www courtinfo ca gov CM 010 Rev L 2007 July C M 010 INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET To Plaintiffs and Others Filing First Papers If you are filing a first paper for example a complaint in a civil case you must complete and file along with your first paper the Civil Case Cover Sheet contained on page 1 This information will be used to compile statistics about the types and numbers of cases filed You must complete items 1 through 6 on the sheet In item 1 you must check one box for the case type that best describes the case If the case fits both a general and a more specific type of case listed in item 1 check the more specific one If the case has multiple causes of action check the box that best indicates the primary cause of action To assist you in completing the sheet examples of the cases that belong under each case type in item 1 are provided below A cover sheet must be filed only with your initial paper Failure to file a cover sheet with the first paper filed in a civil case may subject a party its counsel or both to sanctions under rules 2 30 and 3 220 of the California Rules of Court To Parties in Rule 3 740 Collections Cases A collections case under rule 3 740 is defined as an action for recovery of money owed in a sum stated to be certain that is not more than 25 000 exclusive of interest and attorney s fees arising from a transaction in which property services or money was acquired on credit A collections case does not include an action seeking the following 1 tort damages 2 punitive damages 3 recovery of real property 4 recovery of personal property or 5 a prejudgment writ of attachment The identification of a case as a rule 3 740 collections case on this form means that it will be exempt from the general time for service requirements and case management rules unless a defendant files a responsive pleading A rule 3 740 collections case will be subject to the requirements for service and obtaining a judgment in rule 3 740 To Parties in Complex Cases In complex cases only parties must also use the Civil Case Cover Sheet to designate whether the case is complex If a plaintiff believes the case is complex under rule 3 400 of the California Rules of Court this must be indicated by completing the appropriate boxes in items 1 and 2 If a plaintiff designates a case as complex the cover sheet must be served with the complaint on all parties to the action A defendant may file and serve no later than the time of its first appearance a joinder in the plaintiffs designation a counter designation that the case is not complex or if the plaintiff has made no designation a designation that the CaSe iS Complex CASE TYPES AND EXAMPLES Auto Tort Contract Provisionally Complex Civil Litigation Cal Auto 22 Personal Injury Property Breach of Contract Warranty 06 Rules of Court Rules 3 400 3 403 Damage Wrongful Death Breach of Rental Lease Antitrust Trade Regulation 03 Uninsured Motorist 46 if the Contract not unlawful detainer Construction Defect 10 case involves an uninsured or wrongful eviction Claims Involving Mass Tort 40 motorist claim subject to ContracUWarranty Breach Seller Securities Litigation 28 arbitration check this item Plaintiff not fraud ornegligence Environmental Toxic Tort 30 instead of Auto Negligent Breach of ContracU Insurance Coverage Claims Other PI PD WD Personal lnjury Warranty arising from provisionally complex Other Breach of ContracUWarranty case type listed above 41 Property Damage Wrongful Death Tort Collections e money g owed open Enforcement of Judgment Asbestos 04 book accounts 09 Enforcement of Judgment 20 Asbestos Collection Case Seller Plaintiff Abstract of Judgment Out of Property Damage Asbestos Personal Injury Other Promissory Note Collections County Wrongful Death Case Confession of Judgment non Insurance Coverage not provisionally domestic relations Product Liability not asbestos or complex 18 Sister State Judgment toxic nvironmental 24 Medical Malpractice 45 Auto Subrogation Administrative Agency Award Medical Malpractice Other Coverage not unpaid taxes Physicians Surgeons Other Contract 37 Petition Certification of Entry of Other Professional Health Care Contractual Fraud Judgment on Unpaid Taxes Malpractice Other Contract Dispute Other Enforcement of Judgment Case Other PI PD WD 23 Real Property Premises Eminent Domain Inverse Miscellaneous Civil Complaint Liability e g slip Condemnation RICO 27 and fall 14 Intentional Bodily Injury PDlWD Wrongful Eviction 33 Other Complaint not specified e above 42 g assault vandalism Other Real Property e g quiet title 26 Intentional Infliction of Writ of Possession of Real Property Declaratory Relief Only Emotional Distress Mortgage Foreclosure Injunctive Relief Only non Negligent Infliction of harassment Quiet Title Emotional Distress Mechanics Lien Other Real Property not eminent Other PI PD WD domain Other Commercial Complaint landlord tenant or Non PI PD WD Other Tort Case non tort non complex foreclosure Other Civil Complaint Business Tort Unfair Business Unlawful Detainer non tort non complex Practice 07 Commercial 31 Miscellaneous Civil Petition Civil Rights e g discrimination Residential 32 false Partnership and Corporate arrest not civil Drugs 38 if the case involves illegal Governance 21 harassment 08 drugs check this item otherwise Defamation Other Petition not specified e g slander libel report as Commercial or Residential above 43 13 Judicial Review Civil Harassment Fraud 16 Asset Forfeiture 05 Workplace Violence Intellectual Property 19 Petition Re Arbitration Award 11 Elder Dependent Adult Professional Negligence 25 Writ of Mandate 02 Abuse Legal Malpractice Writ Administrative Mandamus Election Contest Other Professional Malpractice Writ Mandamus on Limited Court Petition for Name Change not medical or legal Case Matter Petition for Relief From Late Other Non PI PD WD Tort 35 Writ Other Limited Court Case Claim Employment Review Other Civil Petition Wrongful Termination 36 Other Judicial Review 39 Other Employment 15 Review of Heaith O cer Order Notice of Appeal Labor Commissioner Appeals CM 010 Rev July L 2007 Page 2 of 2 CIVIL CASE COVER SHEET